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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 Commission's 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 site's topography could impact the site's 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: Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street
Nashville, TN  37243-1532
Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance
Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution
Robert J. Duncan II Vice President
H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy Electronic Mail Distribution
Brian C. McCabe
Manager, Nuclear Oversight Shearon Harris Nuclear Power Plant Progress Energy Electronic Mail Distribution
Scott D. West Superintendent Security H. B. Robinson Steam Electric Plant Progress Energy Electronic Mail Distribution
 
Joseph W. Donahue Vice President Nuclear Oversight Progress Energy
Electronic Mail Distribution
David T. Conley Senior Counsel Legal Department Progress Energy Electronic Mail Distribution
 
John H. O'Neill, Jr. Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC  20037-1128 Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and
Environmental Control Electronic Mail Distribution
Kelvin Henderson General Manager
Nuclear Fleet Operations Progress Energy Electronic Mail Distribution
Thomas Cosgrove Plant General Manager H.B. Robinson Steam Electric Plant, Unit 2
Progress Energy Electronic Mail Distribution
Donna B. Alexander Manager, Nuclear Regulatory Affairs
(interim) Progress Energy Electronic Mail Distribution
Robert P. Gruber
Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC  27699-4326
W. Lee Cox, III Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources
Electronic Mail Distribution
Greg Kilpatrick Operations Manager H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy Electronic Mail Distribution
 
cc w/encl. (continued next page)
   
CP&L 4  cc w/encl. (continued) Mark Yeager Division of Radioactive Waste Mgmt. S.C. Department of Health and
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
    John W. Flitter Director of Electric & Gas Regulation South Carolina Office of Regulatory Staff 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
 
 
Enclosure 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 licensee's failure to consider how the aggregate changes to the site's topography could impact the site's 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
licensee's corrective action program as NCR 468235.
The licensee's failure to consider how the aggregate changes to the site's topography could impact the site's 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 site's topography on the site's 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
3  Enclosure 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 operator's 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
licensee's 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, licensee's 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 licensee's failure to consider how the aggregate changes to the site's topography could impact the site's 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 licensee's 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 
5  Enclosure states that due to the site's 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 
6  Enclosure 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 site's 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 licensee's failure to consider how the aggregate changes to the site's topography could impact the site's 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 site's 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 
7  Enclosure 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 site's 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 site's
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 licensee's 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 site's topography controlled by Unit 1 to ensure review by Unit 2 engineering for impact to design, licensing, and regulatory requirements
* Revise the site's 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.
 
8  Enclosure 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. 
9  Enclosure 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 brigade's 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 
10  Enclosure 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.   
11  Enclosure 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
 
12  Enclosure
* 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
 
13  Enclosure
* 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 licensee's 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 inspector's 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 
14  Enclosure 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, licensee's 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 licensee's 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 licensee's 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. 
15  Enclosure 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 
16  Enclosure
* 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.
   
17  Enclosure .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.
   
18  Enclosure .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 
     
19  Enclosure 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
licensee's 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.
 
 
20  Enclosure 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 licensee's 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; 
21  Enclosure
* 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 licensee's 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 
22  Enclosure 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 
Attachment 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"
4  Attachment 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
 
5  Attachment 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
 
6  Attachment 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 26'A' 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 
7  Attachment 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
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