IR 05000331/2008004

IR 05000331-08-004 on 07/01/2008 - 09/30/2008 for Duane Arnold Energy Center

ML083100167
Person / Time
Site:	Duane Arnold
Issue date:	11/04/2008
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	Richard Anderson Florida Power & Light Co
References
EA-08-154 IR-08-004
Download: ML083100167 (44)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 November 4, 2008

EA-08-154 Mr. Richard Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785 SUBJECT: DUANE ARNOLD ENERGY CENTER NRC INTEGRATED INSPECTION REPORT 05000331/2008004

Dear Mr. Anderson:

On September 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Duane Arnold Energy Center. The enclosed report documents the inspection results, which were discussed on October 9, 2008, with Mr. D. Curtland and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, two NRC-identified findings of very low safety significance were identified. The findings involved violations of NRC requirements. However, because these violations were of very low safety significance, and because the issues were entered into your Corrective Action Program (CAP), the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section VI.A.1 of the NRC Enforcement Policy. Additionally, a licensee identified violation is listed in Section 4OA7 of this report. If you contest the subject or severity of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Duane Arnold Energy Center. 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), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-331 License No. DPR-49 Enclosure: Inspection Report 05000331/2008004 (w/Attachment: Supplemental Information) cc w/encl: M. Nazar, Senior Vice President and Chief Operating Officer J. Stall, Executive Vice President, Nuclear and Chief Nuclear Officer M. Ross, Managing Attorney A. Khanpour, Vice President, Nuclear Engineering M. Warner, Vice President, Nuclear Plant Support D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs M. Mashhadi, Senior Attorney T. Jones, Vice President, Nuclear Operations, Midwest Region P. Wells, Acting Vice President, Nuclear, Training and Performance Improvement R. Hughes, Director, Licensing and Performance Improvement D. McGhee, Iowa Dept. of Public Health Chairman, Linn County, Board of Supervisors Chief Radiological Emergency Preparedness Section, Dept. Of Homeland Security M. Rasmusson, State Liaison Officer

SUMMARY OF FINDINGS

IR 05000331/2008004; 07/01/2008 - 09/30/2008; Duane Arnold Energy Center; Operability Evaluations and Plant Modifications. This report covers a three-month period of inspection by resident and regional inspectors and announced baseline inspections of radiation protection (RP). Two Green findings were identified by the inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (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," Revision 4, dated December 2006.

A. NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

A finding of very low safety significance and associated NCV of Technical Specification (TS) Section 5.4.1.a, associated with Regulatory Guide 1.33, Revision 2, Appendix A, Section 9, was identified by the inspectors when the licensee failed to adequately evaluate a condition adverse to quality prior to the maintenance activity's Environmental Qualification (EQ) Drop Dead Date (DDD). Specifically, the licensee failed to evaluate the Emergency Core Cooling System (ECCS) room cooler fan motors as operable but non-conforming prior to the EQ DDD as required by Duane Arnold's Preventive Maintenance Program procedure. The licensee entered this condition into their CAP as Corrective Action Process document 060543, and declared the equipment operable but non-conforming. This issue is more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesired consequences. Specifically, the failure to correctly assess the ECCS room cooler fan motor bearings as nonconforming with their EQ calculation of record had the potential to impact the availability and reliability of the ECCS room coolers. The inspectors evaluated the finding using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of findings," Table 4a, for the Mitigating Systems Cornerstone. Because the finding was a qualification deficiency confirmed not to result in a loss of operability or functionality, the finding screened as

Green.

This finding has a cross-cutting aspect in the Problem Identification and Resolution (PI&R) component of CAP, because the licensee did not properly classify, prioritize, and evaluate for operability a condition adverse to quality P.1(c). Specifically, the Engineering and Operations Departments failed to classify the ECCS room cooler fan motors as operable but nonconforming. (Section 1R15)

Green.

A finding of very low safety significance and associated NCV of 10 CFR 50 Appendix B, Criterion III, "Design Control" was identified by the inspectors for the licensee's failure to assure that applicable regulatory requirements and design basis were correctly translated into specifications, drawings, procedures and instructions.

Specifically, following installation of a permanent modification to install a high pressure keep fill system for the high pressure coolant injection (HPCI) system discharge piping, the Surveillance Test Procedure (STP) implemented to document performance of Surveillance Requirement (SR) 3.5.1.1 for the HPCI system did not ensure that the minimum requirements for system operability were met. The licensee entered this issue into their CAP as CAP 060168, and invoked SR 3.0.3 to address the potentially missed SR. The issue was more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of design control of permanent modifications and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesired consequences. Specifically, the Operations department did not recognize that the implementation of the surveillance procedure which documented the performance of SR 3.5.1.1 for the HPCI system did not ensure that the minimum requirements for system operability were met and therefore had the potential to impact the availability and reliability of the HPCI system. The inspectors evaluated the finding using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of findings," Table 4a, for the Mitigating Systems Cornerstone.

Because the finding does not represent an actual loss of safety function of a single train, and does not screen as risk significant due to an external initiating event, the finding was screened as very low safety significance (Green). The inspectors also determined that this finding had a cross-cutting aspect in the PI&R component of CAP, because the licensee did not properly classify, prioritize, and evaluate for operability a condition adverse to quality P.1(c). Specifically, the Operations and Engineering Departments failed to recognize that the system conditions established during performance of STP 3.5.1-13 had the potential to preclude performance of the SR and allow the condition to go unrecognized. (Section 1R18)

B. Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by inspectors. The violation was the subject of an investigation by the NRC Office of Investigations. Corrective actions taken by the licensee have been entered into the licensee's CAP. The violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Duane Arnold Energy Center (DAEC) operated at full power for the entire assessment period except for brief down-power maneuvers to accomplish rod pattern adjustments and to conduct planned surveillance testing activities, with the following exception:

• On August 22, 2008, reactor power was lowered to approximately 25 percent to perform planned maintenance on the 'B' Recirculation Motor Generator Set. The reactor was returned to full power on August 24,

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems: * 'B' Standby Filter Unit (SFU) with 'A' SFU out-of-service (OOS) for Planned Maintenance;

• 'A' Core Spray (CS) with 'B' CS OOS for Planned Maintenance;

• 'A' Reactor Recirculation System prior to 'B' Reactor Recirculation System being OOS for Planned Maintenance; and

• 'B' CS with 'A' CS OOS for Planned Maintenance. The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), TS requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment. These inspection activities constituted four partial system walkdown samples as defined in Inspection Procedure (IP) 71111.04-05.

4 Enclosure

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• Area Fire Plan (AFP) 03, Reactor Building HPCI, RCIC [Reactor Core Isolation Cooling] & Radwaste Tank Rooms, Elevations 716'-9" through 747'-0";

• AFP 13, Reactor Building Refueling Floor, Elevation 855'-0";

• AFP 14, North Turbine Building Basement Reactor Feed Pump Area & Turbine Lube Oil Tank Area, Elevation 734'-0";

• AFP 23, Control Building Battery Rooms 1D-1, 1D-2, 1D-4 and Battery Corridor, Elevation 757'-6";

• AFP 27, Control Building Control Room HVAC [Heating, Ventilation, and Air Conditioning] Room, Elevation 800'-4"; and

• AFP 69, 70, 71, & 72, Main Yard Main Transformer 1X1, Auxiliary Transformer 1X2, Startup Transformer 1X3, & Standby Transformer 1X4. The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These inspection activities constituted six annual fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings of significance were identified.

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the Attachment to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensee's corrective action documents with respect to past flood-related items identified in the CAP to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant areas to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• Northwest Corner ECCS Room and Torus Area. This inspection activity constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On August 11 and August 18, 2008, the inspectors observed two crews of licensed operators in the plant's simulator during licensed operator requalification (LOR) examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crew's clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• group dynamics and simulator fidelity;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection activity constituted one quarterly LOR sample as defined in IP 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• River Water Supply System; and

• Average Power Range Monitors System. The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. These inspection activities constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

7 Enclosure

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Emergent Work due to a Failure of CV-1065B, the Moisture Separator Reheat (MSR) Drain Valve, During Work Week 9829;

• Emergent Work on the 'A' SFU, with the Unit Inoperable due to a Leaking Deluge Valve, During Work Week 9831;

• Planned Risk Significant Activities During Work Week 9832;

• Planned Corrective Maintenance Activities Requiring Single Loop Operation of the Plant During Work Weeks 9834 and 9835; and

• Planned Corrective Maintenance Activities on a Condensate Storage Tank Level Switch, Impacting both the HPCI and RCIC Systems During Work Week 9838. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. These inspection activities constituted five samples as defined in IP 71111.13-05.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Offsite Power Operable but Degraded;

• Control Building Chiller Low Oil Level and Low Combined Oil Pressure;

• Water Leakage into the Reactor Building during Roof Repair and Impact on Secondary Containment; and

• Environmental Qualification (EQ) Preventative Maintenance Tasks for Reactor Building ECCS Room Cooling Units approaching their Drop-Dead Date. The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensee's evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment to this report. These inspection activities constituted four samples as defined in IP 71111.15-05.

b. Findings

Inadequate Assessment of ECCS Room Cooler Fan Motor Bearing Nonconforming Condition

Introduction:

A finding of very low safety significance and associated NCV of TSs was identified by the inspectors for the Engineering and Operations Departments failing to follow the requirements of Administrative Control Procedure (ACP) 1208.3, Preventative Maintenance Program.

Description:

On August 25, 2008, Engineering initiated CAP 059812 identifying that EQ tasks to replace the motor bearings in 1VAC011-M and 1VAC012-M, the ECCS room cooler fan motors, were approaching their Drop Dead Dates (DDD) of September 1, 2008, and September 27, 2008, respectively. The Shift Manager requested an operability determination be performed to evaluate the ECCS room cooler fan motors after the EQ task had passed its DDD. OPR 384 was completed by engineering and approved by the Shift Manager on August 28, 2008. This OPR classified 1VAC011-M and 1VAC012-M as operable but nonconforming. On September 2, 2008, Engineering completed, and the Shift Manager approved, revision 1 to OPR 384. This revision classified 1VAC011-M and 1VAC012-M as fully operable. OPR 384 extended the due date for the EQ task to March 13, 2009, for both fan motors. The ECCS room coolers are safety-related equipment that support the operability of the Residual Heat Removal and Core Spray pumps located in the ECCS corner rooms. The room cooler's motors fall under the requirements of 10 CFR 50.49 for EQ of electrical equipment important to safety for nuclear power plants. Equipment Qualification Record QUAL-W120-05, revision 6, documents the EQ of 1VAC011-M and 1VAC012-M. This 9 Enclosure qualification record stated that the "motor bearings are qualified for 40 years provided that the grease is fully repacked after 12 years of service or the bearings are replaced every 12 years." Duane Arnold's ACP 1208.3 requires that for "EQ replacement (component, o-ring, etc.) where life is limited by aging/evaluation, replacement must be completed by the EQ DDD." This ACP also requires that "effort should be made to both initiate and evaluate ARs [CAPs] prior to exceeding the -EQ DDD." Contrary to this requirement, engineering and operations personnel failed to adequately classify the ECCS room cooler fan motors as operable but nonconforming prior to their EQ DDD when OPR 384, revision 1, classified the fan motors as fully operable.

Analysis:

The inspectors determined that the failure to adequately assess the operability of the ECCS room cooler fan motor bearings prior to their EQ DDD was contrary to NRC's Part 9900 Technical Guidance, "Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," and was a performance deficiency. The finding was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesired consequences. Specifically, the failure to correctly assess the ECCS room cooler fan motor bearings as nonconforming had the potential to impact the availability and reliability of the ECCS room coolers. The inspectors evaluated the finding using the NRC's SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of findings," Table 4a, for the Mitigating Systems Cornerstone. Because the finding was a qualification deficiency confirmed not to result in a loss of operability or functionality, the finding screened as Green. This finding has a cross-cutting aspect in the PI&R component of CAP, because the licensee did not properly classify, prioritize, and evaluate for operability a condition adverse to quality. Specifically, the Engineering and Operations Departments failed to classify the ECCS room cooler fan motors as operable but nonconforming. P.1(c)

Enforcement:

TS Section 5.4.1 states, in part, that "Written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978." Paragraph 9 of this Regulatory Guide states, in part, that procedures for performing maintenance shall be prepared and activities shall be performed in accordance with these procedures. The licensee established ACP 1208.3, Preventive Maintenance Program, as the implementing procedure for performing preventive maintenance. Additionally, ACP 1208.3 states that efforts shall be made to evaluate conditions adverse to quality prior to their EQ DDD. Contrary to the above, on September 2, 2008, the licensee failed to adequately evaluate a condition adverse to quality prior to the EQ DDD. Specifically, Engineering recommended, and Operations approved, an operability determination that incorrectly classified the ECCS room cooler fan motor bearings as fully operable when the EQ DDD 10 Enclosure for fan motor 1VAC011-M was September 1, 2008. Because this violation was of very low safety significance and it was entered into the licensee's CAP as CAP 060543, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000331/2008004-01).

1R18 Plant Modifications

.1 Permanent Plant Modifications

a. Inspection Scope

The following engineering design package was reviewed and selected aspects were discussed with engineering personnel:

• HPCI High Pressure Keep Fill System Installation This document and related documentation were reviewed for adequacy of the associated 10 CFR 50.59 safety evaluation screening, consideration of design parameters, implementation of the modification, post-modification testing, and relevant procedures, design, and licensing documents were properly updated. The inspectors observed ongoing and completed work activities to verify that installation was consistent with the design control documents. The modification, in part, installed a 12 inch swing check valve (V23-0081) between the HPCI pump discharge outboard isolation valve (normally open MO2311) and the inboard isolation valve (normally closed MO2312), and components to allow the condensate service water system to pressurize the portion of the HPCI discharge piping between V23-0081 and MO2312. This inspection activity constituted one permanent modification sample as defined in IP 71111.18-05.

b. Findings

Introduction:

A finding of very low safety significance and associated NCV of 10 CFR 50 Appendix B, Criterion III, "Design Control" was identified by the inspectors for the licensee's failure to assure that applicable regulatory requirements and design basis were correctly translated into specifications, drawings, procedures and instructions. Specifically, following installation of a permanent modification to install a high pressure keep fill system for the HPCI discharge piping, the STP implemented to document performance of Surveillance Requirement (SR) 3.5.1.1 for the HPCI system did not ensure that the minimum requirements for system operability were met.

Description:

On September 7, 2007, the licensee completed installation of a permanent modification to provide a high pressure keep fill system for the HPCI discharge piping. One of the activities associated with implementing the permanent modification was the development and implementation of a specific procedure, STP 3.5.1-13, HPCI System Water Fill Test. This STP is used to document performance of SR 3.5.1.1 for the HPCI system. SR 3.5.1.1 states, "Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve." and has a specified Frequency of 31 days. The inspectors reviewed STP 3.5.1-13 to determine if the 11 Enclosure procedure adequately performed SR 3.5.1.1 for the HPCI system within the specified frequency. The following items were identified during the review:

1) The system was vented from the high point vent until a steady flow of water was observed through the sight-flow indicator. However, the high pressure keep fill system continuously remained in service during performance of the procedure. This condition precludes the section of the HPCI system discharge piping from the pump discharge to the discharge check valve from being included as part of the venting flow path since the check valve remained seated throughout the evolution.

2) The procedure only required any one of the three possible pressure sources (pump suction aligned to the condensate storage tanks (CSTs) with the level of water in at least one of the CSTs being greater than or equal to 8 feet, the low pressure keep fill system in service, or the high pressure keep fill in service) to be in use as a prerequisite to performing the venting evolution. This does not ensure that required static head of water is available during the evolution to maintain the piping full of water from the HPCI pump discharge to the HPCI pump discharge check valve.

3) The only step in the STP designated as a required TS compliance item was the actual venting from the system high point vent to obtain a solid stream of water. The action of documenting the level of water in at least one of the CSTs as being greater than or equal to eight feet, or having the low pressure keep fill system in service was not designated as a required TS compliance item, was only a prerequisite item, and was not required to successfully complete the STP.

The combination of the above items had the potential to establish conditions whereby the STP could be completed satisfactorily, without actually performing the SR to verify all discharge piping full of water. This would result in an unrecognized condition where the SR was not performed within the specified Frequency.

Following discussions between the inspectors, Engineering personnel, and Operations personnel on September 10, 2008, this issue was entered into the CAP as CAP 060168. The Shift Manager invoked SR 3.0.3 to address the potentially missed SR and also requested a condition evaluation be performed to determine which portions of the HPCI discharge piping were actually verified filled with water during the monthly performance of STP 3.5.1-13. The licensee's evaluation determined that the HPCI System Operability Test, STP 3.5.1-05, which is performed quarterly, should adequately vent the HPCI discharge piping between the pump discharge and the discharge check valve through the test return valve to the CSTs. By a combination of the two STPs, the SR to verify all the discharge piping filled with water may be considered performed on a quarterly basis. However, this does not meet the 31 day specified Frequency for SR 3.5.1.1. The inspectors performed a review of all the STP 3.5.1-13 surveillances performed between September 2007 and September 2008, and noted that in all cases the CST levels were recorded in the prerequisite section of the STPs, and that the levels were greater than 15 feet. The inspectors determined that, based upon the data recorded during the previous surveillances, the HPCI past operability was not in question.

Analysis:

The inspectors determined that the failure to assure that applicable regulatory requirements and design basis were correctly translated into specifications, drawings, 12 Enclosure procedures and instructions constituted a performance deficiency warranting further review. The finding was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of design control of permanent modifications and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesired consequences. Specifically, the Operations department did not recognize that the implementation of the surveillance procedure which documented the performance of SR 3.5.1.1 for the HPCI system did not ensure that the minimum requirements for system operability were met and had the potential to impact the availability and reliability of the HPCI system. The inspectors evaluated the finding using the NRC's SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of findings," Table 4a, for the Mitigating Systems Cornerstone. Because the finding did not represent an actual loss of safety function of a single train, and did not screen as risk significant due to an external initiating event, the finding was of very low safety significance (Green). The inspectors determined that this finding had a cross-cutting aspect in the PI&R component of CAP, because the licensee did not properly classify, prioritize, and evaluate for operability a condition adverse to quality. Specifically, the Operations and Engineering Departments failed to recognize that the system conditions established during performance of STP 3.5.1-13 had the potential to preclude performance of the SR and the condition go unrecognized. P.1(c)

Enforcement:

10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, following completion of the permanent modification to install a high pressure keep fill system for the HPCI discharge piping in September 2007, the licensee failed to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the STP implemented to document performance of SR 3.5.1.1 for the HPCI system, did not ensure that the minimum requirements for system operability were met.

Because this violation was of very low safety significance and the issue was entered into the licensee's CAP as CAP 060158, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000331/2008004-02).

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• Preventative Work Order PWO 1144461, Overhaul MO-2005 Operator;

• Corrective Work Order CWO A82747, Replace Positioner for CV1065B-O;

• PWO 1146466, Replace Activated Charcoal for 'A' SFU;

• CWO A77315, Repack Containment Isolation Valve CV4313;

• CWO A83648, Replace 'B' Recirculation Motor Generator Set Tachometer Generator; and

• CWO A801745, Replace Existing Model EGPI003 Relay with Newer Model EGPI004 Relay. These activities were selected based upon the SSCs ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion), and test documentation was properly evaluated. The inspectors evaluated the activities against TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety.

Documents reviewed are listed in the Attachment to this report. These inspection activities constituted six samples as defined in IP 71111.19-05.

b. Findings

No findings of significance were identified.

1R21 Component Design Bases Inspection

.1 (Discussed) Violation (VIO) 05000331/2005010-01:

Failure to Demonstrate Adequacy of Design Assumption for Torus Attached Piping.

The inspector initiated a review of licensee corrective actions pertaining to VIO 05000331/2005010-01 that resulted from an unresolved item (URI) identified during the 2004 engineering inspection. Specifically, a design change that modified the HPCI turbine exhaust subsystem was not subject to the design control measures commensurate with those applied to the original design, and the licensee did not implement any measures to verify the adequacy of the design assumption which differed from that applied to the original design.

The inspector initiated in-office review of licensee documentation that included a reanalysis of the 1996 modification to the HPCI subsystem, ECP 1575, which allowed valve V22-0016 to be relocated approximately 50 feet closer to the torus, commensurate with DAEC's plant unique design and licensing bases specific to torus attached piping systems.

14 Enclosure At the conclusion of this inspection period, the licensee's evaluation and resolution of inspector identified issues had not been completed. Inspector review of activities related to VIO 05000331/2005010-01 will be documented in a subsequent inspection period.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• Surveillance Test Procedure (STP) 3.5.1-03B, B CS System Simulated Automatic Actuation (routine);

• STP 3.5.1-04, Low Pressure Core Injection (LPCI) Simulated Auto Actuation (routine);

• STP 3.5.3-02, RCIC Operability Test (IST);

• STP 3.3.8.1-01, 4160 Volt Degraded Voltage Relays (routine);

• STP 3.3.8.1-06A, 1A3 Bus Degraded Voltage Relays Functional Test (routine);

and

• STP 3.4.1-02 and STP 3.4.9-03 for Single Loop Operations (routine). The inspectors observed in-plant activities and reviewed procedures and associated records to determine whether: any preconditioning occurred; effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; as-left setpoints were within required ranges; and the calibration frequency were in accordance with TSs, the USAR, procedures, and applicable commitments; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used; test data and results were accurate, complete, within limits, and valid; test equipment was removed after testing; where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers Code, and reference values were consistent with the system design basis; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure; where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished; prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test; equipment was returned to a position or status required to support the performance of its safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the CAP. Documents reviewed are listed in the Attachment to this report.

15 Enclosure These inspection activities constituted five routine surveillance testing samples and one inservice inspection sample as defined in IP 71111.22, sections -02 and -05.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

Cornerstone: Emergency Preparedness

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on September 17, 2008, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Control Room Simulator and the Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report. This inspection activity constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

===Cornerstone: Occupational Radiation Safety 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

=

a. Inspection Scope

The inspectors reviewed the licensee's UFSAR to identify applicable radiation monitors associated with measuring transient high and very high radiation areas, including those intended for remote emergency assessment. The inspectors identified the types of portable radiation detection instrumentation that were used for job coverage of high radiation area work, including instruments for underwater surveys; portable and fixed area radiation monitors that were used to provide radiological information in various plant areas; and continuous air monitors that were used to assess airborne radiological conditions and work areas with the potential for workers to receive a 50 millirem or greater committed effective dose equivalent (CEDE). Whole body counters that were 16 Enclosure used to monitor for internal exposure and those radiation detection instruments that were used to conduct surveys for the release of personnel and equipment from the radiologically controlled area (RCA), including contamination monitors and portal monitors, were also identified. This inspection constituted two samples as defined in IP 71121.03-5.

b. Findings

No findings of significance were identified.

.2 Calibration and Testing of Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors reviewed radiological instrumentation to determine if it had been calibrated as required by the licensee's procedures, consistent with industry and regulatory standards. The inspectors also reviewed alarm setpoints for selected instruments to determine whether they were established consistent with the UFSAR or TSs, as applicable, and with industry practices and regulatory guidance. Specifically, the inspectors reviewed calibration procedures and the most recent calibration records for the following radiation monitoring instrumentation and calibration equipment:

• J. L. Shepherd portable instrument calibrator Model 28-5D;

• J. L. Shepherd portable instrument calibrator Model 89;

• Eberline Radiation Detection Device Model RM-14s;

• RADOS RTM 950 portal monitors;

• Area Radiation Monitor MGPI DRM-1;

• General Electric (GE) area radiation monitors;

• Eberline AMS-3 continuous air monitors; and

• Victoreen Model 876A containment radiation monitor. The inspectors determined what actions were taken when, during calibration or source checks, an instrument was found significantly out of calibration or exceeded as-found acceptance criteria. Should that occur, the inspectors determined whether the licensee's actions would include a determination of the instruments previous uses and the possible consequences of that use since the prior successful calibration. The inspectors also reviewed the results of the licensee's most recent 10 CFR Part 61 source term (radionuclide mix) evaluations to determine if the radiation sources that were used for instrument calibration and for instrument checks were representative of the plant source term.

The inspectors observed the licensee's use of the portable survey instrument calibration units, discussed calibrator output validation methods, and compared calibrator exposed readings with calculated/expected values. The inspectors evaluated compliance with licensee procedures while RP personnel demonstrated the methods for performing source checks of portable survey instruments and source checks of personnel contamination and portal monitors. This inspection constituted one sample as defined in IP 71121.03-5.

17 Enclosure

b. Findings

No findings of significance were identified.

.3 Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed licensee CAP documents and any Licensee Event Reports or special reports that involved personnel contamination monitor alarms due to personnel internal exposures to determine whether identified problems were entered into the CAP for resolution.

While no internal exposure with a CEDE greater than 50 millirem occurred since the last inspection in this area, the inspectors reviewed the licensee's methods for internal dose assessment to determine if affected personnel would be properly monitored using calibrated equipment and if the data would be analyzed and exposures properly assessed. This inspection constitutes one sample as defined in IP 71121.03-5. The inspectors reviewed CAP reports related to exposure significant radiological incidents that involved radiation monitoring instrument deficiencies since the last inspection in this area, as applicable. Members of the RP staff were interviewed and corrective action documents were reviewed to determine whether follow-up activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk based on the following:

• Initial problem identification, characterization, and tracking;

• Disposition of operability/reportability issues;

• Evaluation of safety significance/risk and priority for resolution;

• Identification of repetitive problems;

• Identification of contributing causes;

• Identification and implementation of effective corrective actions;

• Resolution of NCVs tracked in the corrective action system; and

• Implementation/consideration of risk significant operational experience feedback. This inspection constitutes one sample as defined in IP 71121.03-5. The inspectors determined if the licensee's self-assessment and audit activities completed for the approximate 2-year period that preceded the inspection were identifying and addressing repetitive deficiencies or significant individual deficiencies in PI&R, as applicable. This inspection constituted one sample as defined in IP 71121.03-5.

b. Findings

No findings of significance were identified.

18 Enclosure

.4 Radiation Protection Technician Instrument Use

a. Inspection Scope

The inspectors verified that calibrations for those survey instruments used to perform job coverage surveys and for those currently designated for use had not lapsed. The inspectors determined if response checks of portable survey instruments and checks of instruments used for unconditional release of materials and workers from the RCA were completed prior to instrument use, as required by the licensee's procedure. The inspectors also discussed instrument calibration methods and source response check practices with RP staff and observed staff demonstrate instrument source checks. This inspection constituted one sample as defined in IP 71121.03-5.

b. Findings

No findings of significance were identified.

.5 Self-Contained Breathing Apparatus Maintenance and Emergency Response Staff Qualifications

a. Inspection Scope

The inspectors reviewed the status and surveillance records of self-contained breathing apparatus (SCBAs) that were staged in the plant and ready-for-use and evaluated the licensee's capabilities for refilling and transporting SCBA air bottles to-and-from the control room and operations support center during emergency conditions. The inspectors determined if control room staff and other emergency response and RP personnel were trained, respirator fit tested, and medically certified to use SCBAs, including personal bottle change-out. Additionally, the inspectors reviewed SCBA qualification records for numerous members of the licensee's radiological emergency teams to determine if a sufficient number of staff were qualified to fulfill emergency response positions, consistent with the licensee's emergency plan and the requirements of 10 CFR 50.47. This inspection constitutes one sample as defined in P 71121.03-5. The inspectors reviewed the qualification documentation for at least 50 percent of the onsite, or as applicable, offsite contract personnel that performed maintenance on manufacturer designated vital SCBA components. The inspectors also reviewed vital component maintenance records for several SCBA units that were designated as ready-for-use. The inspectors also evaluated, through record review and observations, if the required air cylinder hydrostatic testing was documented and current and if the Department of Transportation required retest air cylinder markings were in place for several randomly selected SCBA units and spare air bottles. The inspectors reviewed the onsite maintenance procedures governing vital component work, as applicable, including those for the low-pressure alarm and pressure-demand air regulator. The inspectors reviewed the licensee's maintenance procedures and the SCBA manufacturer's recommended practices to determine if there were any inconsistencies between them.

19 Enclosure This inspection constituted one sample as defined in IP 71121.03-5.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the second Quarter 2008 performance indicators (PIs) for any obvious inconsistencies prior to its public release in accordance with IMC 0608, "Performance Indicator Program." This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings of significance were identified.

===Cornerstone: Mitigating Systems

=

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC Power System performance for the period from the fourth quarter 2007 through the second quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used. The inspectors reviewed the licensee's operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the Attachment to this report. This inspection activity constituted one MSPI emergency AC power system sample as defined in IP 71151-05.

20 Enclosure

b. Findings

No findings of significance were identified.

.3 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - High Pressure Injection Systems PI for the period from the fourth quarter 2007 through the second quarter 2008.

To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used. The inspectors reviewed the licensee's operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the Attachment to this report. This inspection activity constituted one MSPI high pressure injection system sample as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

.4 Mitigating Systems Performance Index - Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Heat Removal System performance indicator for the period from the fourth quarter 2007 through the second quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC Integrated Inspection reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the Attachment to this report. This inspection activity constituted one MSPI heat removal system sample as defined in IP 71151-05.

21 Enclosure

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of items Entered Into the CAP

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensee's CAP as a result of the inspectors' observations are included in the attached List of Documents Reviewed. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings of significance were identified.

.2 Daily CAP Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP. This review was accomplished through inspection of the station's daily condition report packages. These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

22 Enclosure

b. Findings

No findings of significance were identified.

.3 Annual Sample:

Review of Operator Workarounds

a. Inspection Scope

The inspectors evaluated the licensee's implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the Operator Workarounds (OWAs) on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents. The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment were reviewed to accomplish the objectives of the IP. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP and proposed or implemented appropriate and timely corrective actions, which addressed each issue. Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds. The above activity constituted completion of one operator workarounds annual inspection sample as defined in IP 71152-05.

b. Findings

No findings of significance were identified.

.4 Selected Issue Follow-Up Inspection:

Fire Brigade Training Effectiveness

a. Inspection Scope

During a review of items entered in the licensee's CAP, the inspectors recognized corrective action items documenting unsatisfactory fire drill performance by the fire brigade team on two separate occasions within the past four months. On August 12, 2008, the inspectors observed fire brigade activation, in response to a simulated fire in the Standby Transformer, which was conducted as a remediation drill for the unsatisfactory drill conducted the previous week. Based on this observation, the inspectors evaluated the fire brigade training program effectiveness to ensure the plant fire brigade capability to combat fires. Documents reviewed are listed in the Attachment to this report.

23 Enclosure The above activity constituted completion of one in-depth PI&R annual sample as defined in IP 71152-05. b. Observations and Assessments The inspectors observed both fire brigade drill performance and the management and staff's evaluation activities to identify deficiencies, openly discuss them in a self-critical manner at the drill debrief, and take appropriate corrective actions as required. Specific attributes evaluated by the inspectors were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses;

(3) effectiveness of fire brigade leader communications, command, and control;

(4) adherence to the pre planned drill scenario; and

(5) drill objectives. Additionally, the inspectors assessed the adequacy of the fire brigade training program requirements identified in 10 CFR 50 Appendix R Section I, the site Fire Plan Volume II - Fire Brigade Organization, and the licensee's design basis document for the fire protection program, DBD P72-001, Revision B. During observation of the August 12, 2008, drill and post-drill debrief, the inspectors noted several challenges in the areas of general equipment use and command and control. The drill debriefs were led and conducted by the Fire Marshall with minimal participation by the fire brigade team members and did not include a review of the drill training/evaluation objectives. These observations were discussed with the Fire Marshall, Operations Manager, and the Emergency Planning Manager. Corrective actions were identified to improve the effectiveness and learning opportunities of the drills and debriefs, which included having the fire brigade team leader conduct the debriefs, bringing them more in line with emergency planning and operator requalification training evolutions. The inspectors observed two subsequent fire brigade team drill debriefs which occurred following implementation of corrective actions from the August 2008 fire drills. The inspectors noted that the identified deficiencies in the effectiveness of the training and proficiency program for the fire brigade team and members were aggressively resolved, and that the necessary improvements were implemented in a very timely manner.

c. Findings

No findings of significance were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Review of Personnel Performance During a Preplanned Non-Routine Plant Evolution:

Single Loop Operations

a. Inspection Scope

The inspectors reviewed the plant's performance of the infrequently performed evolution of planned single loop operations. On August 22, 2008, the licensee reduced reactor power to approximately 25 percent and secured the 'B' reactor recirculation loop pump to permit the replacement of the motor generator set degraded tachometer generator. Following the corrective maintenance, the 'B' reactor recirculation loop pump was successfully restarted for post-maintenance testing and the reactor was returned to full 24 Enclosure power on August 24, 2008. Documents reviewed in this inspection are listed in the Attachment.

This inspection constituted one sample as defined in IP 71153-05.

b. Findings

No findings of significance were identified.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of 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 of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On October 9, 2008, the inspectors presented the inspection results to Mr. D. Curtland, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

• Radiation monitoring instrumentation and protective equipment and the close-out of the licensee identified violation were discussed with Mr. R. Anderson, Site Vice President on August 8, 2008.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) was identified by the licensee. This violation meets the criteria of Section VI of the NRC Enforcement Policy, for being dispositioned as an NCV.

25 Enclosure Cornerstone: Occupational Radiation Safety DAEC TS 5.4.1 provides, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33 Revision 2, Appendix A, February 1978. Section 2 of Appendix A to Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," Revision 2, February 1978, provides, in part, that the licensee establish written procedures for preparation for refueling, refueling equipment operation, and core alterations. Section 3.6.3 of DAEC's ACP 1407-2, "Material Control in the Spent Fuel Pool and Cask Pool," Revision 15, a procedure that implements TS 5.4.1 and Regulatory Guide 1.33, provides in part, that health physics must be made aware of what and where any material is being relocated in the spent fuel pool, cask pool or cavity water prior to movement. Contrary to the above, on February 7, 2007, a contract employee relocated reactor cavity lights from the spent fuel pool to the reactor cavity without notifying health physics. The NRC reviewed the incident, interviewed applicable staff, and concluded that the violation was not willful. This inspection activity closed URI 2007002-06.

Because the violation is of very low safety significance, it meets the criteria in Section VI.A.1 of the NRC Enforcement Policy, and it has been entered into the Corrective Action Program (CAP 047066), it is being treated as an NCV. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Anderson, Site Vice President

D. Curtland, Plant Manager

B. Eckes, NOS Manager

S. Catron, Licensing Manager

J. Cadogan, Engineering Director

B. Kindred, Security Manager

J. Morris, Training Manager

C. Dieckmann, Operations Manager

G. Rushworth, Assistant Operations Manager

R. Harter, Operations Support Manager

G. Pry, Maintenance Manager

R. Porter, Chemistry & Radiation Protection Manager (acting)

M. Davis, Emergency Preparedness Manager

G. Ellis, Program Owner, Fire Protection

M. Lingenfelter, Design Engineering Manager

S. Huebsch, System Engineering Supervisor

J. Swales, Design Engineering Supervisor

K. Kleinheinz, Program Engineering Manager

J. Kuehl, Program Engineering Supervisor

D. Albrecht, Radwaste Supervisor

G. Park, ISI Program Owner

F. Dohmen, NDE Level III

B. Klotz, Program Engineering Supervisor

J. Probst, Site Maintenance Rule Coordinator

N. McKenney, General Supervisor Radiation Protection Support

S. Funk, CHP, REMP Program Manager, Sr. Health Physics Coordinator

D. Johnson, Radwaste Operator/Chem Tech, Rad Environmental Technician

S. Matyas, Radiation Protection Program Administration Radiation Monitoring Instrumentation Nuclear Regulatory Commission

K. Feintuck, Project Manager, NRR

K. Riemer, Chief, Reactor Projects Branch 2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000331/2008004-01 NCV Inadequate Assessment of ECCS Room Cooler Fan Motor Bearing Nonconforming Condition (1R15)

05000331/2008004-02 NCV Failure to Perform a TS Surveillance Requirement for the HPCI System Within the Specified Frequency (1R18)

Attachment

Closed

05000331/2008004-01 NCV Inadequate Assessment of ECCS Room Cooler Fan Motor Bearing Nonconforming Condition (1R15)

05000331/2008004-02 NCV Failure to Perform a TS Surveillance Requirement for the HPCI System Within the Specified Frequency (1R18)

05000331/2007002-06 URI Contractor/Supervisor Moving Reactor Cavity Lights from the Spent Fuel Pool to the Reactor Cavity Without Notifying the Health Physics Technician (Section 4OA7)

Discussed

05000331/2005010-01 VIO Failure to Demonstrate Adequacy of Design Assumption for Torus Attached to Piping (1R15.21)

Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. 1R04 Equipment Alignment