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{{Adams
#REDIRECT [[IR 05000261/2011004]]
| number = ML113180464
| issue date = 11/14/2011
| title = IR 05000261-11-004, 05000261-11-502, on 07/01/2011 - 09/30/2011, H.B. Robinson Steam Electric Plant, Unit 2, Adverse Weather Protection and Operability Evaluations
| author name = Musser R
| author affiliation = NRC/RGN-II/DRP/RPB4
| addressee name = Gideon W
| addressee affiliation = Carolina Power & Light Co
| docket = 05000261
| license number = DPR-023
| contact person =
| document report number = IR-11-004, IR-11-502
| document type = Inspection Report, Letter
| page count = 35
}}
See also: [[see also::IR 05000261/2011502]]
 
=Text=
{{#Wiki_filter:UNITED STATES
                              NUCLEAR REGULATORY COMMISSION
                                                REGION II
                            245 PEACHTREE CENTER AVENUE NE, SUITE 1200
                                    ATLANTA, GEORGIA 30303-1257
                                        November 14, 2011
Carolina Power and Light Company
ATTN: Mr. William R. Gideon
Vice President - Robinson Plant
H. B. Robinson Steam Electric Plant
Unit 2
3581 West Entrance Road
Hartsville, SC 29550
SUBJECT:        H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED
                INSPECTION REPORT 05000261/2011004, 05000261/2011502, AND
                ASSESSMENT FOLLOW-UP LETTER
Dear Mr. Gideon:
On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your H.B. Robinson reactor facility. The enclosed integrated inspection report
documents the inspection results, which were discussed on November 14, with Mr. Thomas
Cosgrove 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.
The report documents one self-revealing apparent violation (AV) that has potential safety
significance greater than very low safety significance. The significance of this finding is
designated as To Be Determined (TBD) until the safety characterization has been completed.
This finding is associated with the failure to consider how the aggregate changes to the sites
topography could impact the sites ability to drain storm water runoff and adequately respond to
localized flooding during periods of heavy rain. However, the plant has taken appropriate
interim corrective actions such that the finding does not present an immediate safety concern.
Immediate actions taken by your staff included the removal of the water from the affected plant
buildings and grounds. In addition, within a few weeks of the event, the licensee repaired the
washed out area of the berm just to the north of the power block, and performed interim
adjustments to site topography to limit ponding near the berm.
In addition, the report documents one NRC-identified finding of very low safety significance
(Green). The finding was determined to involve a violation of NRC requirements. However,
because of the very low safety significance and because it is entered into your corrective action
program, the NRC is treating this finding as non-cited violation (NCV) consistent with Section
2.3.2 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response
 
CP&L                                              2
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 H.B. Robinson facility.
On June 9, 2011, the NRC conducted an exit for the IP 95002 supplemental inspection which
was conducted for the three White findings, which placed H.B. Robinson Unit 2 in the Degraded
Cornerstone Column in the third quarter of 2010, as discussed in the assessment letter dated
March 4, 2011. On July 6, 2011, the NRC issued the supplemental inspection report (IR
5000261/2011010, ML # 111870510), which documented that you adequately addressed the
three White findings. As stated in the supplemental inspection report, one finding, specifically
05000261/2010013-01, Failure to Comply with Conduct of Operations Procedure, would still be
considered for agency actions in accordance with the Action Matrix until September 30, 2011.
The NRC determined that as of October 1, 2011, the performance at H.B. Robinson Unit 2 is in
the Licensee Response Column of the Reactor Oversight Process Action Matrix. Although plant
performance is now considered to be within the Licensee Response Column, the NRC has not
yet finalized the significance of apparent violation AV 05000261/2011004-01, Water Intrusion
into Safety-Related Buildings due to Inadequate Design of Site Storm Water Runoff Drainage
System. The final safety significance determination of this issue may change our assessment of
the performance at H.B. Robinson Unit 2.
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 Room or from the Publicly Available Records (PARS) component of NRC's document
system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
                                              Sincerely,
                                              /RA/
                                              Randall A. Musser, Chief
                                              Reactor Projects Branch 4
                                              Division of Reactor Projects
Docket No.: 50-261
License No.: DPR-23
Enclosure:      Inspection Report 05000261/2011004, 05000261/2011502
                  w/Attachment: Supplemental Information
cc w\encl:      See page 3
 
 
__ML113180464____________                  X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED
OFFICE            RII:DRP        RII:DRP      RII:DRP        RII:DRP        RII:DRP          RII:DRP      RII:DRS
SIGNATURE          JGW1 by email  /NA/          JAH5 by email  CBS by email    ETC1 by email    JDA by email  MSC2 by email
NAME              JWorosilo      JDodson      JHickey        CScott          ECoffman        JAustin      MCoursey
DATE                  11/14/2011  11/  /2011      11/03/2011      11/14/2011      11/14/2011      11/03/2011    11/14/2011
E-MAIL COPY?        YES    NO    YES      NO  YES      NO    YES      NO    YES      NO      YES      NO  YES      NO
OFFICE            RII:DRS        RII:DRP      RII:DRP
SIGNATURE          CRS1 by email  TEC1 by email RAM
NAME              CStancil        TChandler    RMusser
DATE                  11/03/2011      11/04/2011    11/14/2011      11/  /2011      11/  /2011
E-MAIL COPY?        YES    NO    YES      NO  YES      NO    YES      NO    YES      NO      YES      NO  YES      NO
       
CP&L                                      3
cc w/encl:                                  Richard Haynes
Division of Radiological Health              Director, Division of Waste Management
TN Dept. of Environment & Conservation      Bureau of Land and Waste Management
401 Church Street                            S.C. Department of Health and
Nashville, TN 37243-1532                    Environmental Control
                                            Electronic Mail Distribution
Sandra Threatt, Manager
Nuclear Response and Emergency              Kelvin Henderson
Environmental Surveillance                  General Manager
Bureau of Land and Waste Management          Nuclear Fleet Operations
Department of Health and Environmental      Progress Energy
Control                                      Electronic Mail Distribution
Electronic Mail Distribution
                                            Thomas Cosgrove
Robert J. Duncan II                          Plant General Manager
Vice President                              H.B. Robinson Steam Electric Plant, Unit 2
H.B. Robinson Steam Electric Plant, Unit 2  Progress Energy
Progress Energy                              Electronic Mail Distribution
Electronic Mail Distribution
                                            Donna B. Alexander
Brian C. McCabe                              Manager, Nuclear Regulatory Affairs
Manager, Nuclear Oversight                  (interim)
Shearon Harris Nuclear Power Plant          Progress Energy
Progress Energy                              Electronic Mail Distribution
Electronic Mail Distribution
                                            Robert P. Gruber
Scott D. West                                Executive Director
Superintendent Security                      Public Staff - NCUC
H. B. Robinson Steam Electric Plant          4326 Mail Service Center
Progress Energy                              Raleigh, NC 27699-4326
Electronic Mail Distribution
                                            W. Lee Cox, III
Joseph W. Donahue                            Section Chief
Vice President                              Radiation Protection Section
Nuclear Oversight                            N.C. Department of Environmental
Progress Energy                              Commerce & Natural Resources
Electronic Mail Distribution                Electronic Mail Distribution
David T. Conley                              Greg Kilpatrick
Senior Counsel                              Operations Manager
Legal Department                            H.B. Robinson Steam Electric Plant, Unit 2
Progress Energy                              Progress Energy
Electronic Mail Distribution                Electronic Mail Distribution
John H. O'Neill, Jr.                        cc w/encl. (continued next page)
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, NW
Washington, DC 20037-1128
 
CP&L                                        4
cc w/encl. (continued)                        John W. Flitter
Mark Yeager                                  Director of Electric & Gas Regulation
Division of Radioactive Waste Mgmt.          South Carolina Office of Regulatory Staff
S.C. Department of Health and                Electronic Mail Distribution
Environmental Control
Electronic Mail Distribution
Public Service Commission
State of South Carolina
P.O. Box 11649
Columbia, SC 29211
Chairman
North Carolina Utilities Commission
Electronic Mail Distribution
Henry Curry
Training Manager
H.B. Robinson Steam Electric Plant, Unit 2
Progress Energy
Electronic Mail Distribution
Senior Resident Inspector
U.S. Nuclear Regulatory Commission
H. B. Robinson Steam Electric Plant
2112 Old Camden Rd
Hartsville, SC 29550
William R. Gideon
Director Site Operations
H. B. Robinson Steam Electric Plant, Unit 2
Progress Energy
Electronic Mail Distribution
Christos Kamilaris
Manager, Support Services
H.B. Robinson Steam Electric Plant, Unit 2
Progress Energy
Electronic Mail Distribution
Rich Rogalski
Supervisor, Licensing/Regulatory Programs
H. B. Robinson Steam Electric Plant
Electronic Mail Distribution
 
CP&L                                          5
Letter to William R. Gideon from Randall A. Musser dated November 14, 2011
SUBJECT:        H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED
                INSPECTION REPORT 05000261/2011004, 05000261/2011502, AND
                ASSESSMENT FOLLOW-UP LETTER
Distribution w/encl:
C. Evans, RII EICS
L. Douglas, RII EICS
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMRobinson Resource
 
            U. S. NUCLEAR REGULATORY COMMISSION
                                REGION II
Docket No:        50-261
License No:        DPR-23
Report No:        005000261/2011004, 05000261/2011502
Facility:          H. B. Robinson Steam Electric Plant, Unit 2
Location:          3581 West Entrance Road
                  Hartsville, SC 29550
Dates:            July 1, 2011 through September 30, 2011
Inspectors:        J. Hickey, Senior Resident Inspector
                  T. Chandler, Acting Senior Resident Inspector
                  C. Scott, Resident Inspector
                  E. Coffman, Resident Inspector, V.C. Summer
                  M. Coursey, Reactor Inspector
                  C. Stancil, Resident Inspector, Browns Ferry
                  J. Austin, Senior Resident Inspector, Harris
Approved by:      R. Musser, Chief
                  Reactor Projects Branch 4
                  Division of Reactor Projects
                                                                Enclosure
 
                                      SUMMARY OF FINDINGS
IR 05000261/2011004, 05000261/2011502, 07/01/2011 - 09/30/2011; H.B. Robinson Steam
Electric Plant, Unit 2; Adverse Weather Protection and Operability Evaluations.
The report covered a three month period of inspection by several resident inspectors and one
reactor inspector. One AV and one NCV were identified. The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)
0609, Significance Determination Process (SDP). The cross-cutting aspects were determined
using IMC 0310, Components within the Cross-Cutting Areas. Findings for which the SDP
does not apply may be Green or be assigned a severity level after NRC management review.
A. NRC-Identified and Self-Revealing Findings
    Cornerstone: Initiating Events
    *  TBD. A self-revealing apparent violation (AV) of 10 CFR 50, Appendix B, Criterion III,
        Design Control, was identified for the licensees failure to consider how the aggregate
        changes to the sites topography could impact the sites ability to drain storm water
        runoff and adequately respond to localized flooding during periods of heavy rain. This
        resulted in the ponding of storm water runoff, the subsequent direction of runoff flow
        towards the power block, overfilling of the retention basin, backup of the storm drainage
        system, and ultimately, uncontrolled water intrusion into safety-related equipment rooms
        in the auxiliary building. The licensee took immediate actions to remove the water from
        the affected plant buildings and grounds. In addition, within a few weeks of the event,
        the licensee repaired the washed out area of the berm just to the north of the power
        block, and performed interim adjustments to site topography to limit ponding near the
        berm. The licensee plans to perform additional site grade and trench restoration and
        remediation to permanently prevent site ponding. This issue was entered into the
        licensees corrective action program as NCR 468235.
        The licensees failure to consider how the aggregate changes to the sites topography
        could impact the sites ability to drain storm water runoff and adequately respond to
        localized flooding during periods of heavy rain as required by procedure EGR-NGGC-
        0005, Engineering Change, was a performance deficiency. This performance
        deficiency was considered more than minor because it was associated with the Initiating
        Events Cornerstone attributes of the Design Control (plant modifications) and Protection
        Against External Factors (flood hazard), and adversely affected the cornerstone
        objective to limit the likelihood of those events that upset plant stability and challenge
        critical safety functions during shutdown as well as power operations. Specifically, the
        failure to consider aggregate changes to the sites topography on the sites ability to
        drain storm water runoff resulted in uncontrolled water intrusion into safety-related
        equipment rooms. The inspectors assessed the finding using Inspection Manual
        Chapter (IMC) 0609, Significance Determination Process (SDP), Att. 4, Phase 1 - Initial
        Screening and Characterization of Findings, and determined the finding was potentially
        greater than very low safety significance because the finding increases the likelihood of
        an external flooding event. As a result, the characterization worksheet for Initiating
        Events required a Phase 3 analysis using the Individual Plant Examination for External
                                                                                            Enclosure
 
                                                3
      Event Submittal (IPEEE) or other existing plant specific analyses as inputs. The
      significance of this finding is designated as To Be Determined (TBD) until the safety
      characterization has been completed by the NRC Senior Reactor Analyst (SRA). The
      inspectors determined that the cause of this finding was related to the trending and
      assessment aspect in the Corrective Action Program component of the Problem
      Identification and Resolution cross-cutting area. (P.1(b)) (Section 1R01)
  Cornerstone: Mitigating Systems
  *  Green. The inspectors identified a Green NCV of Technical Specification (TS) 5.4.1,
      Administrative Controls, Procedures, for failure to establish procedural guidance to
      monitor Service Water System (SWS) parameters and operate the SWS strainers
      following a loss of offsite power (LOOP). Following a LOOP, the operators ability to
      recover from a plugged SWS strainer would be impacted due to the loss of the
      associated control alarm and the lack of procedural guidance to manually operate the
      SWS strainers. The licensee has revised plant procedures to include additional
      instructions that will ensure that operators can recover from plugged SWS strainers and
      preserve the operation of the SWS following a LOOP. This issue was entered into the
      licensees corrective action program as NCR 473900.
      The failure to establish procedural guidance to locally monitor SWS parameters and
      manually operate the SWS strainers following a LOOP was a performance deficiency.
      This issue was more than minor because if left uncorrected this finding would have the
      potential to lead to a more significant safety concern. Specifically, the inability to clean
      the service water strainers, following a prolonged LOOP, could impact the operation of
      the service water system. The SDP Phase 1 screening determined that this finding was
      within the mitigating systems cornerstone and was potentially risk significant due to a
      seismic, flooding or severe weather initiating event and therefore required a Phase 3
      SDP analysis. An NRC Senior Reactor Analyst (SRA) determined the lack of procedure
      for a loss of the service water strainers due to an external event (i.e., loss of offsite
      power removing power to the strainers and causing debris to clog the system) was of
      very low risk significance i.e., Green. The main contributors to the low risk results were:
      1) the low likelihood of a total loss of service water event, and 2) the probability of
      recovery of the strainers and/or the system despite the lack of procedures. The
      inspectors determined that the finding has a cross-cutting aspect in the Corrective Action
      Program component of the Problem Identification and Resolution area, because the
      licensee failed to thoroughly evaluate the issue such that the resolution addressed the
      cause and extent of conditions, as necessary. Specifically, licensees evaluation of the
      NCR associated with the lack of plant procedures to manually operate the SWS, failed to
      recognize that the control room indication associated with a plugged SWS strainer would
      be lost following a LOOP. (P.1(c)) (Section 1R15)
B. Licensee-Identified Violations
  None
                                                                                            Enclosure
 
                                          REPORT DETAILS
Summary of Plant Status: The unit began the inspection period at rated thermal power. On
July 22 a power reduction to 50 percent was initiated for planned maintenance. The unit was
returned to rated thermal power on July 25, 2011. On August 2 power management actions
began in order to control circulating water discharge temperature into Lake Robinson. These
actions resulted in power being cycled by as much as 20 percent and continued until August 15.
The unit operated at full power until September 26 when it tripped due to a failed relay in the C
Reactor Coolant Pump (RCP) breaker. Startup of the unit was initiated on September 29 and
rated thermal power was attained on October 1.
1.      REACTOR SAFETY
        Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1      External Flooding
        (Closed) URI 05000261/2011003-1, Rainstorm Results in Flooding of the Power Block
  a.  Inspection Scope
        The inspectors previously opened URI 05000261/2011003-01, Rainstorm Results in
        Flooding of the Power Block, in NRC Integrated Inspection Report 05000261/2011003.
        The inspectors performed a review of the Updated Final Safety Analysis Report
        (UFSAR), the IPEEE, the root cause evaluation report for NCR 468235, and calculation
        RNP-F/PSA-0009, Assessment of Internally Initiated Flood Events.
  b.  Findings
        Introduction. A self-revealing apparent violation (AV) of 10 CFR 50, Appendix B,
        Criterion III, Design Control, was identified for the licensees failure to consider how the
        aggregate changes to the sites topography could impact the sites ability to drain storm
        water runoff and adequately respond to localized flooding during periods of heavy rain.
        This performance deficiency resulted in the ponding of storm water runoff, the
        subsequent direction of runoff flow towards the power block, overfilling of the retention
        basin, backup of the storm drainage system, and ultimately, uncontrolled water intrusion
        into safety-related equipment rooms in the auxiliary building. The licensee took
        immediate actions to remove the water from the affected plant buildings and grounds. In
        addition, within a few weeks of the event, the licensee repaired the washed out area of
        the berm just to the north of the power block, and performed interim adjustments to site
        topography to limit ponding near the berm. The licensee plans to perform additional site
        grade and trench restoration and remediation to permanently prevent site ponding. This
        issue was entered into the licensees corrective action program as NCR 468235.
        Description. The UFSAR for the H.B. Robinson Plant states: Flooding is a physical
        impossibility at this site since the maximum cooling lake level which can be maintained
        by the drain and appurtenant structures is below plant grade. The IPEEE for the plant
                                                                                            Enclosure
 
                                        5
states that due to the sites topography, the probability of a sustained water level of one
foot or more at the Auxiliary Building following the probable maximum precipitation (30
inches in 6 hours - NOAA 1978) is extremely unlikely. On May 27, 2011, the Robinson
Nuclear Plant experienced a heavy rainstorm that resulted in uncontrolled water
intrusion into several safety-related equipment rooms due to external flooding. This
storm produced only 3.71 inches of rain in one 6-hour period, which is only 12 percent of
that assumed in the IPEEE.
The heavy rains caused localized ponding of storm water runoff in the protected area
(PA) and outlying areas of the owner controlled area. From approximately 1200 on May
27, 2011, to 0200 on May 28, 2011, the plant received a total of 5.82 inches of rain, with
3.71 inches being received in the first 6 hours. This initial influx of rain water exceeded
the capacity of the existing storm drain system, and as a result, storm water backed up
into plant buildings, including the A train emergency diesel generator (EDG) room. The
floor drains in the EDG rooms, which are tied directly to the storm drain system, had
been modified in 1994 to add back-flow isolation valves to prevent such an event.
However the back-flow isolation valve in the A EDG room failed to close.
Within the first 2 hours, storm water runoff from the areas north of the plant, which
include the Independent Spent Fuel Storage Installation (24P-ISFSI) pad, the Unit 1
landfill, and the Unit 1 coal pile, began to form a large pond on the north side of the berm
which runs along the protected area (PA) fence on the north side of the plant. At
approximately 1515 on May 27 the first washout of soil occurred from the berm area
south of the ISFSI pad. The washed out soil collected in the storm drains and storm
drain catch basins on the north side of the plant rendering them inoperable. As a result,
several of the buildings on the north side of the power block were flooded with several
inches of water.
At 1530, another larger washout of the same berm occurred in the southeast corner of
the 24P-ISFSI pad allowing additional amounts of soil and storm water runoff to drain
into the north side of the PA. This second washout effectively drained the large pond
north of the berm. Soon after, a third washout occurred in the southwest corner of the
24P-ISFSI pad.
By 1800, the licensee had removed enough soil from the north side of the plant to allow
the 6-8 inches of water that had accumulated up against the power block to drain to the
retention ponds. This draining of the north plant area eventually overflowed both the
Unit 1 (coal plant) and Unit 2 retention basins which had been cross-connected earlier in
an attempt to prevent Unit 2 retention basin from overflowing.
It should be noted that none of the Auxiliary Building internal or external doors are
designed to be watertight, and as a result, water flowed under and around the external
doors on the north and east sides of the building for several hours. However, the
Auxiliary Building sump system minimized the effects of the water ingress until the sump
pumps had to be secured due to high level in the Waste Hold Up Tank. The water level
in the Safety Injection and Containment Spray pump room, which is located against the
north wall of the Auxiliary Building, reached 1-2 inches in depth. Many rooms inside the
Auxiliary Building, including the A EDG room and the hallway that contains one of the
                                                                                    Enclosure
 
                                      6
two safety-related 480 volt ac motor control centers, had 1-2 inches of water on the
floor. The Hot Machine Shop and New Fuel Storage Room, which are located on the
north side of the power block, contained 6-8 inches of standing water.
Within a few hours, the licensee had removed the water from the affected plant buildings
and grounds. In addition, within a few weeks of the event the licensee repaired the
washed out area of the berm and performed interim adjustments to site topography to
limit ponding near the berm. The licensee plans to perform additional site grade and
trench restoration and remediation to permanently prevent site ponding. The licensee
also initiated revisions to procedures to provide adequate guidance for slope and berm
backfill, coordinate site topography changes between Units 1 and 2, and to require
erosion control plans for parking areas, roadways, and drives.
The modifications to the sites topography that led to the May 27, 2011, external flooding
event occurred over several decades, but culminated with the capping of the Unit 2
landfill in April 2010. During the summer of 2010 there were three separate rain events
that caused breaches through the berm on the north side of the PA due to ponding of
storm water runoff. Therefore it can be conservatively assumed that the site was
vulnerable to external flooding events for approximately 13 months before the May 27
event.
Although no safety-related equipment was directly impacted during the May 27 event,
there were 1-2 inches of water in several rooms that contain significant amounts of
safety-related equipment. The majority of the safety-related equipment is mounted
approximately 12 inches above the floor. However, the rain storm on May 27 produced
only 3.71 inches of rain in one 6-hour period, which is only 12 percent of that assumed in
the IPEEE. Had the site received the probable maximum precipitation, the likelihood of
safety related equipment being impacted by raising flood water would have increased.
Analysis. The licensees failure to consider how the aggregate changes to the sites
topography could impact the sites ability to drain storm water runoff and adequately
respond to localized flooding during periods of heavy rain as required by procedure
EGR-NGGC-0005, Engineering Change, was a performance deficiency. Specifically,
the licensee did not follow procedure EGR-NGGC-0005, Engineering Change, which
provides guidance and checklist items to ensure that the aggregate effects of facility
changes on rain water runoff were considered. This performance deficiency was
considered more than minor because it was associated with the Initiating Events
Cornerstone attributes of the Design Control (plant modifications) and Protection Against
External Factors (flood hazard), and adversely affected the cornerstone objective to limit
the likelihood of those events that upset plant stability and challenge critical safety
functions during shutdown as well as power operations. Specifically, the failure to
consider aggregate changes to the sites topography on the sites ability to drain storm
water runoff resulted in uncontrolled water intrusion into safety-related equipment rooms.
The inspectors assessed the finding using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP), Att. 4, Phase 1 - Initial Screening and
Characterization of Findings, and determined the finding was potentially greater than
very low safety significance because the finding increases the likelihood of an external
flooding event. As a result, the characterization worksheet for Initiating Events required
                                                                                    Enclosure
 
                                      7
a Phase 3 analysis using the IPEEE or other existing plant specific analyses as inputs.
The significance of this finding is designated as To Be Determined (TBD) until the safety
characterization has been completed.
The inspectors determined that the cause of this finding was related to the trending and
assessment aspect in the Corrective Action Program component of the Problem
Identification and Resolution cross-cutting area. Specifically, the licensee used less-
than-adequate trending and assessment techniques and thus failed to recognize a
significant number of event pre-cursors that indicated an adverse trend in the sites
ability to control storm water runoff. [P.1(b)]
Enforcement. 10 CFR 50, Appendix B, Criterion III requires in part that the design basis
is correctly translated into drawings and procedures, and the adequacy of design
changes are verified or checked. Site procedure EGR-NGGC-0005, Engineering
Change, is used to implement this regulatory requirement. Contrary to the above, from
November 1966 to April 2010 the licensee made several modifications to the sites
topography without performing adequate design reviews that would have identified the
aggregate effects of the proposed topography changes on storm water runoff. This
resulted in the May 27, 2011, uncontrolled water intrusion into safety-related equipment
rooms. This issue was entered into the licensees corrective action program as NCR
468235. The licensee has initiated the following corrective actions to restore
compliance:
*  Implement an Engineering Change to restore grading and trenching to ensure storm
    runoff in the north plant area is directed to appropriate drains
*  Perform necessary design basis calculations to support compliance with 10 CFR 50,
    Appendix A, Criterion 2, Design bases for protection against natural phenomena
*  Revise the interface agreement between Unit 1 and Unit 2 to coordinate changes to
    the sites topography controlled by Unit 1 to ensure review by Unit 2 engineering for
    impact to design, licensing, and regulatory requirements
*  Revise the sites design change procedures to require a sedimentation and erosion
    control plan when the potential for runoff of disturbed land exists
Pending determination of safety significance, this finding is identified as an apparent
violation (AV) 05000261/2011004-01, Water Intrusion into Safety-Related Buildings due
to Inadequate Design of Site Storm Water Runoff Drainage System.
URI 05000261/2011003-01, Rainstorm Results in Flooding of the Power Block is closed.
                                                                                  Enclosure
 
                                              8
1R04 Equipment Alignment
  a. Inspection Scope
    Partial System Walkdowns:
    The inspectors performed the following three partial system walkdowns, while the
    indicated structures, systems, and/or components (SSCs) were out-of-service for
    maintenance and testing:
    *    'B' motor-driven auxiliary feed water (AFW) pump while 'A' pump was out of service
          for planned maintenance
    *    A Instrument Air System while B Instrument Air Compressor was out of service for
          corrective maintenance
    *    A, B, and C safety injection (SI) pumps after the B and C SI pumps were
          swapped following a test of the B SI pump
    To evaluate the operability of the selected trains or systems under these conditions, the
    inspectors compared observed positions of valves, switches, and electrical power
    breakers to the procedures and drawings listed in the Attachment.
    The inspectors reviewed the following ARs associated with this area to verify that the
    licensee identified and implemented appropriate corrective actions:
    *    477699, Moisture Separator Reheat Purge Valves Found Closed During Normal
          Plant Operation
    *    480007, Clearance Information Tags Hung on Wrong Components
  b. Findings
    No findings were identified.
1R05 Fire Protection
.1  Quarterly Resident Inspector Tours
  a. Inspection Scope
    For the five areas identified below, the inspectors reviewed the control of transient
    combustible material and ignition sources, fire detection and suppression capabilities,
    fire barriers, and any related compensatory measures to verify that those items were
    consistent with Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire
    Protection System, and UFSAR Appendix 9.5.A, Fire Hazards Analysis. The inspectors
    walked down accessible portions of each area and reviewed results from related
    surveillance tests to verify that conditions in these areas were consistent with
    descriptions of the areas in the UFSAR. Documents reviewed are listed in the
    Attachment.
                                                                                        Enclosure
 
                                                9
      The following areas were inspected:
      *    Turbine Building Ground Level (fire zones 25 A&B)
      *    Turbine Building Mezzanine Level (fire zones 25 E&F)
      *    'A' and 'B' Battery Room (fire zone 16)
      *    Safety Injection Pump Room (fire zone 3)
      *    Component Cooling Water Pump Room (fire zone 5)
      The inspectors reviewed the following AR associated with this area to verify that the
      licensee identified and implemented appropriate corrective actions:
      *    486287, Engine Driven Fire Pump Heaters Not Working
  b.  Findings
      No findings were identified.
.2    Annual Fire Protection Drill Observation
  a.  Inspection Scope
    To evaluate the readiness of personnel to prevent and fight fires, the inspectors
    observed fire brigade performance during the announced fire drill in the condensate
    polishing building motor-control center on September 7. This included observing the pre-
    drill briefing for the drill controllers, dress out of the fire brigade members in the fire
    locker, fire brigade performance at the fire scene, and the post-drill critiques for the
    controllers and the fire brigade. The inspectors evaluated the fire brigade performance
    to verify that they responded to the fire in a timely manner, donned proper protective
    clothing, used self-contained breathing apparatus, and had the equipment necessary to
    control and extinguish the fire. The inspectors also assessed the adequacy of the fire
    brigades fire fighting strategy including entry into the fire area, communications, search
    and rescue, and equipment usage.
  b.  Findings
      No findings were identified.
1R06 Flood Protection Measures
  a.  Inspection Scope
      The inspectors walked down the SI pump room and the A emergency diesel generator
      (EDG) room to verify that each area configuration, features, and equipment functions
      were consistent with the descriptions and assumptions used in Calculation RNP-F/PSA-
      0009, Assessment of Internally Initiated Flood Events. Specifically, motor controllers
      and terminal boxes that could become potentially submerged were inspected to ensure
      that the sealing gasket material was intact and undamaged. Those rooms were selected
                                                                                          Enclosure
 
                                            10
    because they contain risk-significant SSCs which are susceptible to flooding from
    postulated pipe breaks. The inspectors also reviewed the operator actions credited in
    the analysis to verify that the desired results could be achieved using the plant
    procedures listed in the Attachment.
    The inspectors reviewed the following ARs associated with this area to verify that the
    licensee identified and implemented appropriate corrective actions:
    *  482434, Potential Adverse Trend in Rainwater Intrusion
    *  476676, Water Present In Manholes M-35 and M-36
b.  Findings
    No findings were identified.
1R11 Licensed Operator Requalification
a.  Inspection Scope
    The inspectors observed licensed-operator performance during requalification simulator
    training to verify that operator performance was consistent with expected operator
    performance, as described in Exercise Guide LOCT 03-4. This training tested the
    operators ability to operate components from the control room, direct auxiliary operator
    actions, and determine the appropriate emergency action level classifications while
    responding to a turbine first stage pressure transmitter failure, manual control of steam
    generator levels, a rod control urgent failure alarm, inadvertent turbine trip/reactor trip
    and a loss of the E-2 safety bus with a failure of the B EDG output breaker to close.
    The inspectors focused on clarity and formality of communication, the use of procedures,
    alarm response, control board manipulations, group dynamics, and supervisory
    oversight.
    The inspectors also observed the simulator exercise freeze critiques to verify that the
    licensee identified deficiencies and discrepancies that occurred during the simulator
    training.
b.  Findings
    No findings were identified.
1R12 Maintenance Effectiveness
a.  Inspection Scope
    The inspectors reviewed the three degraded SSC/function performance problems or
    conditions listed below to verify the appropriate handling of these performance problems
    or conditions in accordance with 10 CFR 50, Appendix B, Criterion XVI, Corrective
    Action, and 10 CFR 50.65, Maintenance Rule. Documents reviewed are listed in the
    Attachment.
                                                                                        Enclosure
 
                                            11
    The problems/conditions and their corresponding ARs were:
    *  474815, C Charging Pump Flow in the Alert Range
    *  478069, Right Turbine Stop Valve Did Not Go Completely Closed During Testing
    *  Overall Performance History of the Dedicated Shutdown Diesel System
    During the reviews, the inspectors focused on the following:
    *  Appropriate work practices,
    *  Identifying and addressing common cause failures,
    *  Scoping in accordance with 10 CFR 50.65(b),
    *  Characterizing reliability issues (performance),
    *  Charging unavailability (performance),
    *  Trending key parameters (condition monitoring),
    *  10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and
    *  Appropriateness of performance criteria for SSCs/functions classified (a)(2) and/or
        appropriateness and adequacy of goals and corrective actions for SSCs/functions
        classified (a)(1).
    The inspectors reviewed the following ARs associated with this area to verify that the
    licensee identified and implemented appropriate corrective actions:
    *  434642, Iso-Phase Bus Loss of Cooling Alarms Spuriously
    *  434646, Steam Generator Feedwater Regulating Valves are Moving in a Jerking
        Motion
b.  Findings
    No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a.  Inspection Scope
    For the six samples listed below, the inspectors reviewed risk assessments and related
    activities to verify that the licensee performed adequate risk assessments and
    implemented appropriate risk-management actions when required by 10 CFR
    50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk
    was promptly assessed, and that appropriate risk-management actions were promptly
    implemented. Documents reviewed are listed in the Attachment. Those periods
    included the following:
    *  July 1, 2011, Emergent work to repair the A and B Charging pump following failure
        of the B Speed Controller and High Stuffing Box Temperature on A Charging Pump
                                                                                    Enclosure
 
                                          12
    *    July 4-11, 2011, Work week included B Charging Pump maintenance, calibration of
          the Refueling Water Storage Tank (RWST) Level Transmitter LT-948, and A
          Instrument Air Compressor maintenance.
    *    July 11-17, 2011, Work week included V2-16C AFW Isolation Valve control switch
          replacement, clean and test the B AFW Pump Oil Cooler, and inspection and
          vibration monitoring of containment cooling fans
    *    July 25-31, 2011, Work week included B SI Pump stud inspection, SI room cooling
          fan HVH-6A inspection, and testing of the A Containment Spray (CS) Pump
    *    August 1-7, 2011, Work week included an unplanned down-power to maintain water
          discharge temperatures, reactor coolant pump seal injection flow transmitter
          calibrations, and C Charging Pump scoop tube adjustment
    *    September 12-19, 2011, Work week included modifications to the Dedicated
          Shutdown Diesel Generator and associated load center, and reactor protection
          system train B logic testing.
    The inspectors reviewed the following ARs associated with this area to verify that the
    licensee identified and implemented appropriate corrective actions:
    *    479209, Several PM Frequencies do not Align with Train Separation
    *    476370, B MDAFW Pump Scheduled Unavailability Time Exceeded
b.  Findings
    No findings were identified.
1R15 Operability Evaluations
a.  Inspection Scope
    The inspectors reviewed the four operability determinations associated with the ARs
    listed below. The inspectors assessed the accuracy of the evaluations, the use and
    control of any necessary compensatory measures, and compliance with the TS. The
    inspectors verified that the operability determinations were made as specified by
    Procedure OPS-NGGC-1305, Operability Determinations. The inspectors compared the
    justifications provided in the determinations to the requirements from the TS, the
    UFSAR, and associated design-basis documents to verify that operability was properly
    justified and the subject components or systems remained available, such that no
    unrecognized increase in risk occurred:
    *    474425, B Charging Pump Speed Control Failed High
    *    485071, A train SI Accumulator leaking
                                                                                      Enclosure
 
                                          13
  *    463149, Manual Operation of the Service Water Header Strainers
  *    463429, Small Service Water Leak at SW-56 (Station Air Compressor Outlet to
        Aftercooler)
  Documents reviewed are listed in the Attachment.
  The inspectors reviewed the following ARs associated with this area to verify that the
  licensee identified and implemented appropriate corrective actions:
  *    482618, MCC-6(10F)-42/C Pick Up Voltage Greater Than Procedure Threshold
  *    483178, Inadequate Heat Removal During Station Battery Capacity Test
b. Findings
  Introduction: The inspectors identified a green NCV of Technical Specification 5.4.1,
  Administrative Controls, Procedures, for the licensees failure to establish adequate
  procedural guidance to monitor SWS parameters and operate the SWS strainers
  following a loss of offsite power (LOOP).
  Description: On May 4, 2011, site engineering wrote a condition report, NCR 463149,
  which identified that plant procedures did not include instructions to manually clean the
  SWS strainers following a LOOP. The NCR noted that the SWS design bases document
  validation report identified that the periodic cleaning of the SWS strainers had to be
  performed using manual operator action following a LOOP. The vendor technical
  manual outlines the procedure for the manual operation of the strainer. However,
  current licensee procedures did not include instructions for operators to manually
  operate the SWS strainers following a LOOP. The licensee initiated actions to update
  current licensee procedures to include guidance to manually clean the strainers and
  closed the associated condition report on May 10, 2011.
  The inspectors reviewed NCR 463149 and the actions associated with its closure. The
  SWS strainers are designed to strain debris from Lake Robinson and support the
  operation of the SWS. The SWS strainers include a motor, wiper, timer and control
  switches which are all powered via, MCC-7, a non-safety related source. The wipers
  have a self-cleaning feature which will automatically start on a high differential pressure
  signal across the strainers. The high differential pressure sensed across the strainers
  would also actuate an alarm in the control room. The inspectors reviewed the
  annunciator response procedure, AP-008, SW Strainer Hi DP, and questioned whether
  the instrumentation required to alert the control room operators was powered from the
  same non-safety related power source as the strainers. The licensee reviewed the
  inspectors concern and determined that the control room alarm associated with the SW
  strainers was also powered by MCC-7. The inspectors were concerned that an external
  event, such as a tornado or hurricane, coincident with a LOOP, may challenge the
  operation of the SWS, due to the lack of control room indication of a plugged strainer.
  The inspectors concluded that, without indication, control room operators would be
  unable to identify the need to take the appropriate actions to manually clean the strainer
  prior to a significant loss of SWS flow. The licensee documented this issue in NCR
                                                                                      Enclosure
 
                                      14
473900 and initiated actions to change plant procedures to include guidance to locally
monitor SWS parameters and manually clean the strainers following a LOOP.
Analysis: The failure to establish adequate procedural guidance to monitor SWS
parameters and manually operate the SWS strainers following a LOOP was a
performance deficiency. The finding was more than minor because if left uncorrected,
the performance deficiency has the potential to lead to a more significant safety concern.
Specifically, the failure to clean the service water strainers, following a LOOP, could
impact the operation of the service water system. A Significance Determination Process
(SDP) Phase 1 screening was performed and determined that this finding was within the
mitigating systems cornerstone and potentially risk significant due to a seismic, flooding
or severe weather initiating event. Consequently a Phase 3 analysis was required. Two
dominant core damage sequences were evaluated. The first dominant accident
sequence consisted of a reactor trip, initiated by a loss of condenser heat sink, and a
subsequent failure to initiate high pressure recirculation, which leads to a RCP seal loss
of coolant accident. The second dominant accident sequence consisted of a LOOP
followed by the failure of the turbine-driven AFW pump and non-recovery of the electrical
system. A senior reactor analyst determined that the lack of a procedure for a loss of
the service water strainers due to an external event (i.e., loss of offsite power removing
power to the strainers and causing debris to clog the system) was of very low risk
significance i.e., Green. The main contributors to the low risk results were: 1) the low
likelihood of a total loss of service water event, and 2) the probability of recovery of the
strainers and/or the system despite the lack of procedures.
The inspectors determined that the finding has a cross-cutting aspect in the Corrective
Action Program component of the Problem Identification and Resolution area, because
the licensee failed to thoroughly evaluate the issue such that the resolution addressed
the cause and extent of conditions, as necessary. Specifically, licensees evaluation of
the NCR associated with the lack of plant procedures to manually operate the SWS,
failed to recognize that the control room indication associated with a plugged SWS
strainer would be lost following a LOOP. (P.1(c))
Enforcement: TS 5.4.1, Administrative Control, Procedures, requires that written
procedures shall be established, implemented, and maintained, covering applicable
procedures recommended in Regulatory Guide 1.33, Appendix A, February 1978.
Section 3 of Regulatory Guide 1.33, Appendix A, February 1978 states that operation of
systems that affect the safety of the nuclear power plant, including the service water
system, should be conducted in accordance with written procedures. The licensee
established, OP-903, Service Water System, as the governing procedure for operation of
the Service Water System. Contrary to the above, on May 4, 2011, it was identified that
the licensees procedure, OP-903, failed to provide adequate guidance for the operation
of the SWS strainers following a LOOP. The licensee revised the plant procedure to
include guidance to locally monitor SWS parameters and manually clean the strainers
following a LOOP. Because this violation was of very low safety significance and it was
entered into the licensees corrective action program (AR 473900), this violation is being
treated as a non-cited violation (NCV), consistent with the NRC Enforcement Policy.
This violation is therefore designated as NCV 05000261/2011004-02, Failure to
Establish Guidance to Monitor and Operate Service Water Strainers Following LOOP.
                                                                                    Enclosure
 
                                            15
1R18 Plant Modifications
.1  Permanent Modification
  a. Inspection Scope
    The inspectors reviewed the permanent modification described in Engineering Change
    81014, C Charging Pump Oil Level Sightglass Installation, to verify that the modification
    design, implementation, and testing did not degrade the design basis, and performance
    capabilities of risk significant equipment and did not place the plant in an unsafe or
    unanalyzed condition. The inspectors verified that the modification satisfied the
    requirements of Procedure EGR-NGGC-005, Engineering Change, and 10 CFR 50,
    Appendix B, Criterion III, Design Control. Documents reviewed are listed in the
    Attachment.
  b. Findings
    No findings were identified.
1R19 Post Maintenance Testing
  a. Inspection Scope
    For the seven post-maintenance tests (PMT) listed below, the inspectors witnessed the
    test and/or reviewed the test data to verify that test results adequately demonstrated
    restoration of the affected safety functions described in the UFSAR and TS. Documents
    reviewed are listed in the Attachment.
    The following tests were witnessed/reviewed:
    *  WO 1496981, Replace CVC-2080, C Charging Pump Suction Relief Valve, PMT in
        accordance with PLP-111, Leak Reduction Program, Rev. 14
    *  WO 1659779, 230 kV Auxiliary Relay Inspection, PMT in accordance with WO
        1659779
    *  WO 1528300, Replace GEMCO Switch on Auxiliary Feedwater Header Discharge to
        Steam Generator C, PMT in accordance with OST-201-2, Motor Driven Auxiliary
        Feedwater System Component Test-Train B, Rev. 29
    *  WO 1957584, Replacement of Control Rod Position Indicator P-10 Module, PMT in
        accordance with WO 1957584
    *  WO 1739819, A Safety Injection Pump Bearing Cooler Cleaning, PMT in
        accordance with OST-151-1, Safety Injection System Components Test - Pump A,
        Rev. 34
    *  WO 1686830, Installation of Auto-Start Circuitry Per EC 69423, PMT in accordance
        with SP-1540, Dedicated Shutdown Diesel Generator Auto Start Functional Test,
        Rev. 3
                                                                                      Enclosure
 
                                          16
    *    WO 1620791, SI Pump B Line and Thrust Bearing Oil Reservoir Repairs, PMT in
          accordance with procedures OST-151-1, Comprehensive Flow Test for Safety
          Injection Pump B, Rev. 17, and OST-155, Safety Injection System Integrity Test,
          Rev. 32
    The inspectors reviewed the following ARs associated with this area to verify that the
    licensee identified and implemented appropriate corrective actions:
    *    478651, V6-12A Failed to Stroke from RTGB during the Performance of PMT
    *    479781, Inadequate PMT Following EC Installation
  b. Findings
    No findings were identified.
1R20 Refueling and Outage Activities
    For the outage that began on September 26 and ended on September 30, the inspectors
    evaluated licensee outage activities as described below to verify that the licensee
    considered risk in developing outage schedules, adhered to administrative risk reduction
    methodologies they developed to control plant configuration, and adhered to operating
    license and technical specification requirements that maintained defense-in-depth. The
    inspectors also verified that the licensee developed mitigation strategies for losses of the
    following key safety functions:
    *    decay heat removal
    *    inventory control
    *    power availability
    *    reactivity control
    *    containment
    Documents reviewed are listed in the Attachment.
.1  Review of Outage Plan
  a. Inspection Scope
    The inspectors reviewed the outage risk control plan to verify that the licensee had
    performed adequate risk assessments, and had implemented appropriate risk-
    management strategies when required by 10 CFR 50.65(a)(4).
  b. Findings
    No findings were identified.
                                                                                      Enclosure
 
                                            17
.2  Licensee Control of Outage Activities
  a. Inspection Scope
    During the outage, the inspectors observed the items or activities described below to
    verify that the licensee maintained defense-in-depth commensurate with the outage risk-
    control plan for key safety functions and applicable technical specifications when taking
    equipment out of service.
    *  Clearance Activities
    *  Electrical Power
    *  Decay Heat Removal (DHR)
    *  Reactivity Control
    *  Fatigue Management
    The inspectors also reviewed responses to emergent work and unexpected conditions to
    verify that resulting configuration changes were controlled in accordance with the outage
    risk control plan, and to verify that control-room operators were kept cognizant of the
    plant configuration.
  b. Findings
    No findings were identified.
.3  Monitoring of Heatup and Startup Activities
  a. Inspection Scope
    Prior to mode changes and on a sampling basis, the inspectors reviewed system lineups
    and/or control board indications to verify that TSs, license conditions, and other
    requirements, commitments, and administrative procedure prerequisites for mode
    changes were met prior to changing modes or plant configurations. Also, the inspectors
    periodically reviewed reactor coolant system (RCS) boundary leakage data, and
    observed the setting of containment integrity to verify that the RCS and containment
    boundaries were in place and had integrity when necessary. The inspectors reviewed
    reactor physics testing results to verify that core operating limit parameters were
    consistent with the design.
  b. Findings
    No findings were identified.
                                                                                      Enclosure
 
                                          18
.4  Identification and Resolution of Problems
  a. Inspection Scope
    Periodically, the inspectors reviewed the items that had been entered into the CAP to
    verify that the licensee had identified problems related to outage activities at an
    appropriate threshold and had entered them into the corrective action program. For the
    significant problems documented in the corrective action program and listed below, the
    inspectors reviewed the results of the investigations to verify that the licensee had
    determined the root cause and implemented appropriate corrective actions, as required
    by 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.
    *  413865, Inoperability of Pressurizer Heaters from B train EDG
  b. Findings
    No findings were identified.
1R22 Surveillance Testing
  a. Inspection Scope
    For the eight surveillance tests listed below, the inspectors witnessed testing and/or
    reviewed the test data to verify that the systems, structures, and components involved in
    these tests satisfied the requirements described in the TS, the UFSAR, and applicable
    licensee procedures, and that the tests demonstrated that the SSCs were capable of
    performing their intended safety functions. Documents reviewed are listed in the
    Attachment.
    *  OST-750-2, Control Room Emergency Ventilation System- Train B, Rev. 18
    *  OST-554, Turbine Bearing Oil System and E-H Control System Hydraulic
        Components Test (Monthly), Rev. 20
    *  OST-413, Temporary Skid Diesel Generator, Rev. 8
    *  OST-551-1, Turbine Valve Test, Rev. 4
    *  SPP-038, Installation, Operation, and Removal of Supplemental Cooling for HVH-1,
        2, 3, & 4, Rev. 11
    Inservice Testing Surveillance
    *  OST-108-3, Comprehensive Flow Test For Boric Acid Pump A, Rev. 12
    *  Containment Isolation Valve Surveillance OST-014, LLRT of Personnel Air Lock
        Door Seals (Within Three Days of Entry When CV Integrity is Required), Rev. 15
                                                                                        Enclosure
 
                                            19
      Reactor Coolant System Leakage Surveillance
      *  OST-051, Reactor Coolant Leakage Evaluation (Every 72 Hours During Steady State
          Operation and Within 12 Hours of Reaching Steady State Operation) Rev. 44
      The inspectors reviewed the following AR associated with this area to verify that the
      licensee identified and implemented appropriate corrective actions:
      *  474876, Increase in Unidentified Reactor Coolant System Leakage
  b. Findings
      No findings were identified.
      Cornerstone: Emergency Preparedness
1EP6  Drill Evaluation
  a. Inspection Scope
      On July 26, 2011, the inspectors observed an emergency preparedness drill to verify
      licensee self-assessment of classification, notification, and protective action
      recommendation development in accordance with 10 CFR 50, Appendix E. The
      inspectors also reviewed the Post-Drill Critique Roll-Up and Review Checklist to verify
      that the licensee properly identified failures in classification, notification and protective
      action recommendation development activities.
  b. Findings
      No findings were identified.
4.    OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
  a. Inspection Scope
      The inspectors verified the PIs identified below. For each PI, the inspectors verified the
      accuracy of the PI data that had been previously reported to the NRC by comparing
      those data to the actual data, as described below. The inspectors also compared the
      licensees basis in reporting each data element to the PI definitions and guidance
      contained in NEI 99-02, Regulatory Assessment Indicator Guideline. In addition, the
      inspectors interviewed licensee personnel associated with collecting, evaluating, and
      distributing these data.
                                                                                            Enclosure
 
                                            20
    Initiating Events Cornerstone
    *    Unplanned Scrams per 7000 critical hours
    *    Unplanned Scrams with Complications
    *    Unplanned Power Changes per 7000 critical hours
    For the period from the first quarter of 2010 through the fourth quarter of 2010, the
    inspectors reviewed a selection of licensee event reports, operator log entries, daily
    reports (including the daily CR descriptions), monthly operating reports, and PI data
    sheets to verify that the licensee had accurately identified the number of scrams and
    unplanned power changes greater than 20 percent that occurred during the subject
    period. The inspectors compared those numbers to the numbers reported by the
    licensee for the PI. The inspectors also reviewed the accuracy of the number of critical
    hours reported, and the licensees basis for crediting normal heat removal capability for
    each of the reported reactor scrams.
  b. Findings
    No findings were identified.
4OA2 Identification and Resolution of Problems
.1  Routine Review of ARs
  a. Inspection Scope
    To aid in the identification of repetitive equipment failures or specific human performance
    issues for follow-up, the inspectors performed frequent screenings of items entered into
    the CAP. The review was accomplished by reviewing daily AR reports.
  b. Findings
    No findings were identified.
.2  Annual Sample Review
  a. Inspection Scope
    The inspectors selected AR 463241, Response to AR 422989, Decline in Corrective
    Action Program (CAP) Performance noted similarities with the Davis Besse CAP decline
    lessons learned for detailed review. The inspectors reviewed this report to verify:
    *    complete and accurate identification of the problem in a timely manner;
    *    evaluation and disposition of performance issues;
    *    evaluation and disposition of operability and reportability issues;
    *    consideration of extent of condition, generic implications, common cause, and
          previous occurrences;
                                                                                      Enclosure
 
                                            21
      *  appropriate classification and prioritization of the problem;
      *  identification of root and contributing causes of the problem;
      *  identification of corrective actions which were appropriately focused to correct the
          problem; and
      *  completion of corrective actions in a timely manner.
  b. Observations and Findings
      No findings were identified. The inspectors noted that licensees review of the corrective
      actions implemented as a result of the Davis Besse reactor vessel head degradation
      was thorough and comprehensive. The licensee determined that some corrective
      actions involving ongoing periodic reviews of the event with staff had lost the clear
      linkage of the Davis Besse event with the purpose of the reviews. The licensee added
      additional guidance to directly link the Davis Besse event to the review session.
.3    In-Depth Review of Operator Workarounds
  a.  Inspection Scope
      The inspectors performed a detailed review of the Operator Workarounds and Operator
      Burdens List as of July 28, 2011, to verify the full extent of the issues were identified, an
      appropriate evaluation was performed, and appropriate corrective actions were specified
      and prioritized. The inspectors reviewed and walked down selected Caution Tags to
      assess the impact to the operators. The inspectors met with Operations management to
      discuss the current status of the Operator Workaround and Operator Burdens list.
  b. Findings
      No findings were identified.
4OA3 Event Follow-up
.1    (Closed) LER 2011-001-00, Condition Prohibited by Technical Specifications When
      Non-Seismic System was Aligned to Refueling Water Storage Tank due to Regulatory
      Requirements not Adequately Incorporated in Plant Documentation.
      On May 4, 2011, the licensee determined that over the last 40 years, the plant
      periodically performed cleanup of the Refueling Water Storage Tank (RWST) by aligning
      the non-seismically qualified refueling water purification system to the safety-related and
      seismically qualified RWST without recognizing that the action rendered the RWST
      inoperable. As a result, on multiple occasions the RWST was inoperable for a period
      longer than allowed by Technical Specifications. The cause of this event was that
      regulatory requirements for the separation of seismically qualified and non-seismically
      qualified SSCs were not adequately incorporated into the Design Basis Document and
      the UFSAR. The inspectors reviewed the corrective actions and determined that they
      were adequate. The enforcement aspects of this LER were documented in IR
      05000261/2011003, Section 1R15, as a Green NCV 05000261/2011003-03. The LER
                                                                                        Enclosure
 
                                            22
    was reviewed and no additional findings were identified and no additional violations of
    NRC requirements occurred. This LER is closed.
4OA5 Other Activities
.1  Quarterly Resident Inspector Observations of Security Personnel and Activities
  a. Inspection Scope
    During the inspection period, the inspectors observed Security force personnel and
    activities to ensure that the activities were consistent with licensee security procedures
    and regulatory requirements relating to nuclear plant security. These observations took
    place during both normal and off-normal plant working hours.
    These quarterly resident inspector observations of security force personnel and activities
    did not constitute any additional inspection samples. Rather, they were considered an
    integral part of the inspectors normal plant status review and inspection activities.
  b. Findings
    No findings were indentified.
.2  Operation of an Independent Spent Fuel Storage Installation (ISFSI)
  a. Inspection Scope
    The inspectors performed a walkdown of the two ISFSIs on site (reference dockets 72-3
    and 72-60) and monitored the activities associated with the dry fuel storage campaign
    conducted July 11 through July 15. The inspectors also reviewed changes made to
    programs and procedures and their associated 10 CFR 72.48 screens and/or
    evaluations to verify that changes made were consistent with the license or Certificate of
    Compliance; reviewed records to verify that the licensee has recorded and maintained
    the location of each fuel assembly placed in the ISFSIs; and reviewed surveillance
    records to verify that daily surveillance requirements were performed as required by
    technical specifications. Documents reviewed are listed in the attachment.
  b. Findings
    No findings were identified.
4OA6 Meetings, Including Exit
    On November 14, 2011, the resident inspectors presented the inspection results to Mr.
    Thomas Cosgrove and other members of his staff. The inspectors confirmed that
    proprietary information was not provided or examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                                                                        Enclosure
 
                              SUPPLEMENTAL INFORMATION
                                KEY POINTS OF CONTACT
Licensee personnel
R. Buzard, Licensing
T. Cosgrove, Plant General Manager
H. Curry, Training Manager
S. Garrity, Environmental & Chemistry Superintendent
W. Gideon, Vice President
K. Drown, Nuclear Assurance Manager
B. Houston, Radiation Protection Superintendent
C. Kamilaris, Manager, Support Services - Nuclear
G. Kilpatrick, Operations Manager
L. Martin, Engineering Manager
B. Matherne, Outage & Scheduling Manager
C. Morris, Maintenance Manager
NRC personnel
R. Musser, Chief, Reactor Projects Branch 4
                                                      Attachment
 
            LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000261/2011004-01    AV    Water Intrusion into Safety-Related Buildings due to
                              Inadequate Design of Site Storm Water Runoff
                              Drainage System (Section 1R01)
Closed
05000261/2011003-01    URI  Rainstorm Results in Flooding of the Power Block
                              (Section 1R01)
05000261/2011-001-00  LER  Condition Prohibited by Technical Specifications
                              When Non-Seismic System was Aligned to Refueling
                              Water Storage Tank due to Regulatory Requirements
                              not Adequately Incorporated in Plant Documentation
                              (Section 4OA3)
Opened & Closed
05000261/2011004-02    NCV  Failure to Take Prompt Corrective Actions to
                              Establish Guidance to Monitor and Operate Service
                              Water Strainers Following LOOP (Section 1R15)
Discussed
None
                                                                          Attachment
 
                              LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Other documents
Calculation RNP-F/PSA-0009 Rev. 1, Assessment of Internally Initiated Flood Events
UFSAR Section 3.4, Water Level (Flood) Design
IPEEE Section 5.4, External Floods
Root Cause Evaluation Report for NCR 468235
Section 1R04: Equipment Alignment
Partial System Walkdown
Procedures
OP-402, Auxiliary Feedwater System, Rev 77
OP-905, Instrument and Air Station System Checklist, Rev. 107, Attachment 10.1
OP-202, Safety Injection and Containment Vessel Spray System, Rev. 86, Attachment 10.1
Other documents
HUN-NGGC-0001, Clearance Information Tags (CIT) Hung on Wrong Components, Rev. 8
Drawing 5379-1082, Safety Injection System Flow Diagram, Rev. 44, Sheets 1-5
G-190200, Instrument & Station Air System Flow Diagram, Rev.34, Sheets 1-10
Section 1R05: Fire Protection
UFSAR Sections of Appendix 9.5.1A
Section 3.7.1 Fire Zone 25A-Turbine Building East Ground Floor
Section 3.7.2 Fire Zone 25B-Turbine Building West Ground Floor
Section 3.7.5 Fire Zone 25E-Turbine Building East Mezzanine
Section 3.7.6 Fire Zone 25F-Turbine Building West Mezzanine
Section 3.1.9 Fire Zone 3-Safety Injection Pump Room
Section 3.3 Component Cooling Pump Room
Section 3.1.5.2 Battery Room
Procedures
FP-001, Fire Emergency, Rev. 59
FP-003, Control of Transient Combustibles, Rev. 26
FP-004, Duties of a Fire Watch, Rev. 14
FP-012, Fire Protection Systems Minimum Equipment and Compensatory Actions, Rev. 13
OMM-002, Fire Protection Manual, Rev. 43
OMM-003, Fire Protection Pre-Plans/Unit 2, Rev. 56
Drawings
HBR2 11937 Sheet 46 Fire Pre-Plan Turbine Building Ground Level
HBR2 11937 Sheet 48 Fire Pre-Plan A&B Aux. Boilers and Associated Fuel Oil Pumps
HBR2 11937 Sheet 58 Fire Pre-Plan Turbine Building Mezzanine Level
HBR2 11937 Sheet 19 Fire Pre-Plan Safety Injection Pump Room
                                                                                  Attachment
 
                                            4
HBR2 11937 Sheet 8 Fire Pre-Plan Component Cooling Pump Room
HBR2 11937 Sheet 25 Fire Pre-Plan A and B Battery Room
Other documents
Fire Drill Scenario 02, Condensate Polishing Building, Rev. 1
Section 1R06: Flood Protection Measures
Procedures
AOP-014 Rev. 30, Component Cooling Water System Malfunction
AOP-022 Rev. 35, Loss of Service Water
AOP-032, Rev. 7, Response to Flooding from the Fire Protection System
Other documents
Calculation RNP-F/PSA-0009 Rev. 1, Assessment of Internally Initiated Flood Events
UFSAR Section 3.4, Water Level (Flood) Design
Section 1R11: Licensed Operator Requalification
Other documents
Exercise Guide LOCT 03-4
Section 1R12: Maintenance Effectiveness
Procedures
MST-932, Low Autostop Oil Pressure and Turbine Stop Valve Closure Testing, Rev. 4
MST-551, Turbine Trip Logic Channel Testing, Rev. 30
OST-551-1, Turbine Valve Test, Rev. 4
OST-101-3, CVCS Component Test Charging Pump C, Rev. 44
Work Orders
1932900, Investigate Source of Reduced C Charging Pump Flow
1849467, Perform Turbine Valve Testing
1959363, Investigate No Turbine Stop Valve Indication
1938034, Repair CVC-277B, B Charging Pump Recirculation Valve Seat Leakage
1635854, Clean and Inspect the DSDG
Action Requests
466923, C Charging Pump Lower than Expected Flow.
478069 Right Turbine Stop Valve Did Not Go Completely Closed During Testing
467439, Recurring DSDG Fuel Pressure and Generator Frequency Outside the Surveillance
          Acceptance Criteria
461540, DSDG Cooling Fans Require Blade Guards
460706, A DSDG Ventilation Fan Does Not Start
458851, Wiring Insulation is Nicked
402003, DSDG Operator Logs Revised Prior to Engineering Change Implementation
396769, DSDG Output Breaker Indicating Light is Out
                                                                                  Attachment
 
                                          5
Other documents
Scoping and Performance Criteria for the Dedicated Shutdown Diesel System
Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation
Procedures
OMM-048, Work Coordination and Risk Assessment, Rev. 48
Work Orders
01686830, DSD-GEN Install/Term New Auto Start Components
Action Requests
474424, A Charging Pump Stuffing Box Temp Exceeds Break In Limit
474425, B Charging Pump Speed Controller Failed to Maximum
474549, PIC-402 Guidance Does Not Match Technical Manual
474559, OMM-48, Add Information Concerning Protected Equipment
Other documents
Operating Logs
Risk Profile for July 4 through July 11
Section 1R15: Operability Evaluations
Procedures
AOP-22, Loss of Service Water, Rev.34
PLP-026, Corrective Action Program, Rev. 5
APP-008-F7, South SW HDR LO PRESS, Rev.55
APP-008-F5, SW STRAINER A/B HI P
Action Requests
474425, B Charging Pump Speed Control Failed High
485071, A train SI accumulator leaking
463149, Manual Operation of the Service Water Header Strainers
473900, Monitoring of SW Strainer DP After Loop
Other documents
Quick Cause Evaluation Report for NCR 485071
Service Water Generic Letter 89-13 Item IV-Single Failure Analysis, 1/23/91
CPR 11000005, Service Water System Design Bases Validation Report
OPS-NGGC-1305, Service Water Leak at SWS-56, Rev. 5
Section 1R18: Plant Modifications
Other documents
EC 81014, C Charging Pump Oil Level Sightglass Installation
EC 79219, Oil Level Sight Gage on Charging Pumps
                                                                            Attachment
 
                                            6
Section 1R19: Post Maintenance Testing
Procedures
OST-201-2, MDAFW System Component Test- Train B, Rev. 29
SP-1540, Dedicated Shutdown Diesel Generator Auto Start Functional Test, Rev. 3
PLP-033, Post-Maintenance Testing (PMT) Program, Rev. 54
OST-151-1, Comprehensive Flow Test for Safety Injection Pump B, Rev. 17
OST-155, Safety Injection System Integrity Test, Rev. 32
OST-910, Dedicated Shutdown Diesel Generator (Monthly), Rev. 48
Work Orders
WO 1528301-01, Replace CS/AFW-V2-20A GEMCO Control Switch
WO 1528300-01, Replace GEMCO Switch CS/AFW-V2-16C
WO 1620791, SI Pump B Line and Thrust Bearing Oil Reservoir Repairs
Action Requests
476370, B MDAFW Pump Scheduled Unavailability Time Exceeded
476065, Incorrect Gasket Fit for MDAFW Pump Lube Oil CLR
Other documents
EC 69423, Installation of Auto Start Equipment for DS Diesel Generator, Rev. 8
Section 1R20: Refueling and Outage Activities
Action Requests
490132, Pressurizer Backup Group B Heaters Failed to Energize
490143, Upper Trip Contact Closed on UAT PH-B Differential Relay
490180, FCV-488 Excessive Leak-by on Rx Trip
490184, B Main Feedwater Pump Tripped on Plant Trip
490403, Unable to Completely Isolate Steam Flow to Main Turbine
490524, Rod L-5 Rod Bottom Light Cleared while Rod was Inserted
Other documents
EC 82964, Temporarily Disable Fire Detection Zone 26A Train Detection
Section 1R22: Surveillance Testing
Procedures
OST-750-2, Control Room Emergency Ventilation Train B, Rev. 18
OST-554, Turbine Bearing Oil System and E-H Control System Hydraulic Components Test
(Monthly), Rev. 20
OST-413, Temporary Skid Diesel Generator, Rev. 8
OST-551-1, Turbine Valve Test, Rev. 4
SPP-038, Installation, Operation, and Removal of Supplemental Cooling for HVH-1, 2, 3, & 4,
Rev. 11
Other documents
SD-036, System Description: HVAC System, Rev. 13
UFSAR Section 9.4, Air Conditioning, Heating, Cooling, and Ventilation System, Rev. 22
                                                                                  Attachment
 
                                          7
Section 1EP6: Drill Evaluation
Other documents
Emergency Response Organization Exercise Scenario Package for 07-26-2011
Emergency Notification Forms for the 07-26-2011 Exercise
Section 4OA1: Performance Indicator Verification
Other documents
Operator logs
Section 4OA2: Identification and Resolution of Problems
Procedures
CAP-NGGC-0200, Corrective Action Program, Rev. 34
CAP-NGGC-0206, Corrective Action Program Trending and Analysis, Rev. 5
Action Requests
463241, Davis Besse Lessons Learned Corrective Action Review
422989, Robinson CAP Performance Decline
Section 4OA5 Other Activities
Procedures
ISFS-012, 24P-ISFSI Transfer Cask Handling Operations for Fuel Loading, Rev.12
AOP-028, [Independent Spent Fuel Storage Installation] Abnormal Events, Rev. 8
Action Requests
476365, Trouble Disengaging OS-197 RAM Grapple
Other documents
RNP-24PTH-L-1C-HZ11, Fuel Selection Approval Sheet, 2011
RNP-24PTH-L-1C-HZ12, Fuel Selection Approval Sheet, 2011
RNP-24PTH-L-1C-HZ09, Fuel Selection Approval Sheet, 2011
RNP-24PTH-L-1C-HZ14, Fuel Selection Approval Sheet, 2011
RNP-24PTH-L-1C-HZ13, Fuel Selection Approval Sheet, 2011
                                                                              Attachment
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