ML14087A366

IR 05000266-14-007, 05000301-14-007; 02/03/2014 - 03/06/2014; Point Beach Nuclear Plant, Units 1 and 2; Supplemental Inspection -Inspection Procedure (IP) 95002, Supplemental Inspection for One Degraded Cornerstone..

ML14087A366
Person / Time
Site:	Point Beach
Issue date:	03/28/2014
From:	Boland A Division Reactor Projects III
To:	Mccartney E Point Beach
References
EA-12-009, EA-13-125 IR-14-007
Download: ML14087A366 (58)

See also: IR 05000266/2014007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

March 28, 2014

EA-12-009

EA-13-125

Mr. Eric McCartney

Site Vice President

NextEra Energy Point Beach, LLC

6610 Nuclear Road

Two Rivers, WI 54241

SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

NRC 95002 SUPPLEMENTAL INSPECTION REPORT

05000266/2014007; 05000301/2014007

Dear Mr. McCartney:

On March 6, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a follow-up

supplemental inspection pursuant to Inspection Procedure 95002, Supplemental Inspection for

One Degraded Cornerstone or any Three White Inputs in a Strategic Performance Area, at

your Point Beach Nuclear Plant, Units 1 and 2. The enclosed report documents the results of

this inspection, which were discussed at the exit on March 6, 2014, with you and other members

of your staff.

In accordance with the NRC Reactor Oversight Process (ROP), this follow-up supplemental

inspection was performed to assess the White inspection finding for the failure of the Unit 1

Turbine Driven Auxiliary Feedwater Pump (TDAFWP) and the White inspection finding for

external wave run-up flooding. These two White findings both in the Mitigating Systems

Cornerstone placed Point Beach Unit 1 in a degraded cornerstone as of the first quarter of

2013. In addition to these two White findings we requested that you also include in your

assessment the White finding in the Emergency Preparedness (EP) Cornerstone that had been

issued on July 24, 2012. A 95001, Supplemental Inspection for One or Two Inputs in a

Strategic Performance Area, had previously been performed for the White EP finding and the

White TDAFWP finding.

The NRC staff was informed on October 29, 2013, of your readiness, as of that date for us to

conduct this supplemental inspection.

The objectives of this supplemental inspection were to: (1) provide assurance that the root

causes and the contributing causes for the risk significant issues were understood;

(2) independently assess and provide assurance that the extent of condition and extent of cause

of the individual and collective issues were identified; (3) determine if safety culture components

caused or significantly contributed to the individual or collective issues; and (4) provide

assurance that the corrective actions were or will be sufficient to address and preclude

repetition of the root and contributing causes.

E. McCartney -2-

The inspection consisted of an examination of activities conducted under your license as they

related to safety, compliance with the Commissions rules and regulations, and the conditions of

your operating license. The inspectors reviewed selected procedures and records, observed

activities, and interviewed personnel.

Based on the results of the inspection, the NRC determined that Point Beach had performed an

acceptable evaluation of the White EP finding and the White TDAFWP finding but had not

performed an acceptable evaluation of the White flooding finding and had not performed an

acceptable evaluation of the collective White inputs. Taken collectively the issues associated

with the White flooding finding represented a significant weakness, as discussed in Inspection

Procedure (IP) 95002, and your actions to date have not provided the assurance level required

to meet the inspection objectives. The inspection determined that your staff failed to adequately

evaluate the root causes, contributing causes, extent-of-condition, or extent-of-cause of the

safety-significant finding, and take or plan adequate corrective actions to address the root

causes, contributing causes, extent-of-condition, or extent-of-cause and to prevent recurrence

of the safety-significant finding. The White finding associated with Notice of Violation (NOV)05000266/2013002-10 and 05000301/2013002-10 will be held open. Specific items are

discussed in additional detail in each section of the attached inspection report.

When informed of your readiness, a future inspection will be conducted to verify the corrective

actions that your staff has put in place to address and preclude a repetition of the White flooding

finding.

Based on the results of this inspection, three NRC-identified findings of very low safety

significance (Green) that involved violations of NRC requirements were identified. The NRC

identified an additional Green finding that was associated with a Severity Level IV violation of

NRC requirements evaluated through the traditional enforcement process. However, because

of their very low safety significance, and because these issues were entered into your corrective

action program, the NRC is treating these violations as non-cited violations (NCVs) in

accordance with Section 2.3.2 of the NRC Enforcement Policy.

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 Point Beach Nuclear Plant. In addition, if you disagree with the cross-cutting

aspect assigned to any finding in this report, you should provide a response within 30 days of

the date of this inspection report, with the basis for your disagreement, to the Regional

Administrator, Region III, and the NRC Resident Inspector at the Point Beach Nuclear Plant.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of

cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting

aspects identified in CY 2014 will be coded under the latest revision to Inspection Manual

Chapter (IMC) 0310. Cross-cutting aspects identified in the last six months of 2013 using the

E. McCartney -3-

previous terminology will be converted to the latest revision in accordance with the

cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for

cross-cutting themes and potential substantive cross-cutting issues in accordance with

IMC-0305 starting with the CY 2014 mid-cycle assessment review.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure, and your response (if any) will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Anne T. Boland, Director

Division of Reactor Projects

Docket Nos. 50-266; 50-301

License Nos. DPR-24; DPR-27

Enclosure:

IR 05000266/2014007; 05000301/2014007

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServTM

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 05000266; 05000301

License Nos: DPR-24; DPR-27

Report No: 05000266/2014007; 05000301/2014007

Licensee: NextEra Energy Point Beach, LLC

Facility: Point Beach Nuclear Plant, Units 1 and 2

Location: Two Rivers, WI

Dates: February 3, 2014, through March 6, 2014

Inspectors: B. Bartlett, Project Engineer

J. Beavers, Emergency Preparedness Inspector

R. Elliott, Acting Resident Inspector, Point Beach

J. Jandovitz, Project Engineer

K. Miller, Resident Inspector, Watts Bar

P. Voss, Resident Inspector, Monticello

Approved by: J. Cameron, Chief

Branch 4

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000266/2014007, 05000301/2014007; 02/03/2014 - 03/06/2014;

Point Beach Nuclear Plant, Units 1 and 2; Supplemental Inspection - Inspection Procedure

(IP) 95002, Supplemental Inspection for One Degraded Cornerstone or any Three White Inputs

in a Strategic Performance Area.

This inspection was conducted by three regional inspectors and three resident inspectors. The

inspectors identified three NRC-identified findings of very low safety significance (Green) that

involved violations of NRC requirements. The NRC identified an additional Green finding that

was associated with a Severity Level IV violation of NRC requirements evaluated through the

traditional enforcement process. The significance of most findings is indicated by their color

(Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance

Determination Process (SDP). Assigned 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. The NRCs

program for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

The NRC staff performed this follow-up supplemental inspection in accordance with

Inspection Procedure 95002, Inspection for One Degraded Cornerstone or Any Three

White Inputs in a Strategic Performance Area, to continue to assess the licensees

evaluation of two White inspection findings that affected the Mitigating Systems Cornerstone.

The inspection team determined that the licensee performed an adequate evaluation of some of

the issues, but failed to perform an adequate evaluation of some issues. The inspection team

determined that the root cause evaluation for the Turbine Driven Auxiliary Feedwater Pump

(TDAFWP) appropriately evaluated the root and contributing causes, adequately addressed the

extent of condition and cause, assessed safety culture, and established corrective actions for

the risk significant performance issues. However, the inspection team determined that for the

flooding White finding that the licensee failed to appropriately evaluate the root and contributing

causes, failed to adequately address the extent of condition and cause, failed to adequately

assess safety culture, and failed to establish adequate corrective actions. In addition to

assessing the licensees evaluations, the inspection team independently performed an extent of

condition and extent of cause review of the two findings and a review of the site safety culture

as it related to the root cause evaluations. The team concluded that the licensees root cause

evaluations and corrective actions, both completed and planned, were sufficient to address the

causes and prevent recurrence for the TDAFWP White finding but had significant weaknesses

resulting in failure for the flooding White finding. The licensees implementation of corrective

actions for the TDAFWP will be reviewed during future inspections.

2

A. NRC-Identified and Self-Revealed Findings

• Green. The inspectors identified a finding of very low safety significance and associated

non-citied violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, in

that from March 13, 2013 until February 14, 2014, the licensee failed to assure that for a

significant condition adverse to quality (SQAC), the cause of the condition was

determined and corrective actions were taken to preclude repetition. Specifically, the

licensees corrective actions failed to preclude repetition of an SQAC where Procedure

PC 80 Part 7, Lake Water Level Determination, as implemented, would not protect

safety-related equipment in the turbine building or Circulating Water Pump House

(CWPH). After the licensee had taken corrective actions to improve the wave barrier

procedure in response to an NRC-identified NOV, PC 80 Part 7 and other flood

protection implementing procedures specified inadequate timelines to ensure wave

run-up flood barriers would be installed prior to the lake level at which wave run-up could

impact the site. Corrective actions for this issue included changing the affected

procedures to install the wave barriers at a lower lake level, changing the lake level

determination surveillance from monthly to weekly, and reducing the allowed installation

time for the barriers from 3 weeks to 1 week.

The performance deficiency was screened against the Reactor Oversight Process per

the guidance of lMC 0612, Appendix B, and determined to be more than minor because

the finding was associated with the Mitigating Systems Cornerstone attributes of

Protection Against External Factors (Flood Hazard) and Procedure Quality, and

adversely affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences (i.e. core damage). Specifically, the licensees failure to correct

procedural deficiencies associated with flood barrier construction timelines, could

challenge the timely installation of the barriers, which could impact the ability of

mitigating systems to respond during an external flooding event. The inspectors

evaluated the finding using IMC 0609, Attachment 0609.04, Tables 2 and 3, and

Appendix A. Based on a review of Appendix A, Exhibit 2, Item 4.B, the inspectors

determined that this issue screened as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of problem identification and

resolution, because the licensee failed to thoroughly evaluate issues to ensure that

resolutions address causes and extent of conditions commensurate with their safety

significance. (P.2)

• Green. The inspectors identified a finding of very low safety significance and associated

non-citied violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, in that from January 19, 1996 until November 25, 2013, the

licensee failed to ensure that activities affecting quality were prescribed by documented

procedures of a type appropriate to the circumstances to address external flooding as

described in the Final Safety Analysis Report (FSAR). Specifically, PC 80 Part 7, Lake

Water Level Determination directed advanced installation of concrete barriers to protect

against deep wave action from the lake, which introduced significant unrecognized

blockages in the natural drainage path credited in the FSAR to protect against the

probable maximum precipitation and Turbine Building internal flooding events.

Corrective actions for this issue included changing the procedure and FSAR to include

actions to provide an additional flood relief path through the CWPH building and reliance

on internal flood relief dampers for the affected flooding events.

3

The performance deficiency was screened against the Reactor Oversight Process per

the guidance of lMC 0612, Appendix B, and determined to be more than minor because

the finding was associated with the Mitigating Systems Cornerstone attributes of

Protection Against External Factors (Flood Hazard) and Procedure Quality, and

adversely affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences (i.e. core damage). Specifically, the licensees failure to procedurally

control external flooding design features to ensure they would not adversely affect the

strategy for other flooding events, could negatively impact mitigating systems ability to

respond during external and internal flooding events. The inspectors evaluated the

finding using IMC 0609, Attachment 0609.04, Tables 2 and 3, and Appendix A, and

determined a detailed risk evaluation was required. Following a detailed risk evaluation,

Region III SRAs determined that the finding had very low safety significance (Green).

This finding has a cross-cutting aspect in the area of problem identification and

resolution, because the licensee failed to take effective corrective actions to address

issues in a timely manner commensurate with their safety significance. (P.3)

• Severity Level IV: The inspectors identified a finding of very low safety significance and

associated Severity Level IV, non-citied violation of 10 CFR 50.59(d)(1), Changes, tests

and experiments, when, on November 25, 2013, the licensee failed to perform an

evaluation against the criteria in 10 CFR 50.59(c)(2) for a change to procedure

PC 80 Part 7 to include actions to maintain functionality of drainage paths during

probable maximum precipitation and turbine building flooding events. Specifically,

PC 80 Part 7, Lake Water Level Determination was changed to include actions to open

the CWPH rollup doors to provide an additional drainage path while wave barriers were

in place, without fully evaluating the viability of reliance on additional flood features not

credited for external flooding in the Current License Basis (CLB). Corrective actions for

this issue included to updating the FSAR to describe the new flood paths, performing a

10 CFR 50.59 screening and 10 CFR 50.59 evaluation for the new drainage path which

had put the site outside of the CLB, revising a related functionality assessment,

controlling external flooding areas to ensure they are clear of debris, and creating a

procedure to install curtains on the CWPH rollup doors during periods when they were

required to be open.

The inspectors determined that the licensees failure to fully evaluate the viability of

newly created flooding drainage paths as required by 10 CFR 50.59(d)(1) was a

performance deficiency. The inspectors evaluated the performance deficiency using

traditional enforcement in conjunction with the SDP because the performance deficiency

had the potential to impact the regulatory process. The performance deficiency was

screened per the guidance of lMC 0612, Appendix B, and determined to be more than

minor because the finding was associated with the Mitigating Systems Cornerstone

attributes of Protection Against External Factors (Flood Hazard) and Design Control, and

adversely affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences (i.e. core damage). Specifically, the licensee did not fully demonstrate

that the availability, reliability, and capability of mitigating systems would be maintained

during flooding events due to the sites failure to evaluate the viability of alternate flood

drainage paths through the CWPH. The inspectors evaluated the finding using

IMC 0609, Attachment 0609.04, Tables 2 and 3, and Appendix A. Based on a review of

Appendix A, Exhibit 2, Item 4.B, the inspectors determined that this issue screened as

4

having very low safety significance (Green). Additionally, in accordance with

Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as a

Severity Level IV because the resulting conditions were evaluated as having very low

safety significance (Green) by the SDP. This finding has a cross-cutting aspect in the

area of problem identification and resolution, because the licensee failed to thoroughly

evaluate issues to ensure that resolutions address causes and extent of conditions

commensurate with their safety significance. (P.2)

• Green. The inspectors identified a finding of very low safety significance (Green) and

associated non-citied violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, for the failure to ensure the effectiveness review attributes

for a significant condition adverse to quality would ensure the corrective actions would

eliminate or reduce the recurrence rate.

The inspectors determined that the licensees failure to establish effectiveness review

criteria that would have identified whether the corrective action to prevent recurrence

(CAPRs) had effectively resolved the conditions was a performance deficiency

warranting further review. The inspectors determined that this finding was more than

minor in accordance with IMC 0612, Appendix B, because it was affected the Mitigating

Systems Cornerstone objective to ensure availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences. If left

uncorrected, would the performance deficiency have the potential to lead to a more

significant safety concern? The inspectors evaluated the finding using IMC 0609,

Appendix A. The inspectors determined the finding was of very low safety significance

(Green) because the finding was not a deficiency affecting the design or qualification of

a mitigating structure, system or component and did not result in a loss of operability or

functionality. In addition, the finding did not represent a loss of system or function, did

not represent an actual loss of function of a least a single train for longer than its

technical specification allowed outage time, and did not represent an actual loss of

function of one or more nontechnical specification trains of equipment designated as

high safety-significance.

The finding had a cross cutting aspect in the area of problem identification and

resolution, specifically resolution, because licensee personnel failed to ensure the

corrective actions to prevent recurrence had effective attributes. (P.2)

5

REPORT DETAILS

4. OTHER ACTIVITIES

Cornerstone: Mitigating Systems

4OA4 Supplemental Inspection (95002)

a. Inspection Scope

The NRC staff performed this follow-up supplemental inspection in accordance with

inspection procedure (IP) 95002, Inspection for One Degraded Cornerstone or Any

Three White Inputs in a Strategic Performance Area, to assess the White inspection

finding for the failure of the Unit 1 Turbine Driven Auxiliary Feedwater Pump (TDAFWP)

and the White inspection finding for external wave run-up flooding. In addition to these

two White findings the licensee was requested to also include in their assessment the

White finding in the Emergency Preparedness (EP) Cornerstone that had been issued

on July 24, 2012. A 95001, Supplemental Inspection for One or Two Inputs in a

Strategic Performance Area, had previously been performed for the White EP finding

and the White TDAFWP finding.

The objectives of the supplemental inspection included:

• To provide assurance that the root and contributing causes for the White findings

are understood.

• To determine if the licensees corrective actions for risk-significant performance

issues are sufficient to address the root and contributing causes and prevent

recurrence.

• To independently assess the extent of condition and the extent of cause for

individual and collective risk-significant performance issues.

• To assess the safety culture as a possible contributor.

The inspectors reviewed the Root Cause Evaluations (RCE), in addition to other

assessments, evaluations, and corrective action program documentation completed in

support of and, as a result of, the RCEs. The inspectors reviewed corrective actions that

were taken or planned to address the identified causes. The inspectors interviewed

selected station, corporate, and contractor personnel, and held discussions with these

individuals to verify that the root and contributing causes and the contribution of safety

culture components were understood and that corrective actions taken or planned were

appropriate to address the causes and preclude repetition.

For clarity, documentation of each inspection requirement contains subsections for each

of the two White mitigating systems findings. The White EP finding was assessed by the

inspection team only as it related to commonalities to the other White findings and this is

not individually discussed in this report.

Documents reviewed during this inspection are listed in the Attachment.

6

Inspection Results

The four attributes of IP 95002 were reviewed for each of the three White findings plus

the common cause analysis performed by the licensee. Thus there were a total of 16

attributes that were reviewed. The inspectors concluded that for the White EP finding

and the White TDAFWP finding that the licensee understood the root and contributing

causes. In addition, the inspectors performed the independent extent of condition and

extent of causes and assessed the licensees corrective actions for these two White

findings and concluded that the licensees actions were sufficient. Finally, the inspectors

determined that the safety culture aspects for these two White findings were adequate

although there were safety culture components that contributed to the common cause

analysis conclusions and that corrective actions had been taken to address these

conclusions. Thus of the total of 16 attributes, eight were closed. The inspectors

determined that the root causes, extent of condition, extent of cause, corrective actions

and safety culture aspects for the White flooding finding and the common cause analysis

(CCA) were not sufficient and remain open.

.02 Evaluation of the Inspection Requirements

02.01 Problem Identification

a. Determine that the Evaluation Documented Who Identified the Issue (i.e., Licensee-

Identified, Self-Revealing, or NRC-Identified) and Under What Conditions the Issue was

Identified

The inspectors determined that neither of the RCEs for the two White findings nor the

CCA specifically addressed who identified the issues. The RCE for the TDAFWP White

finding had enough information to infer that the finding was self-revealed but the RCE for

the flooding White finding contained only a minimal inference that a NRC finding had

been issued. The CCA had remarks similar to the flooding RCE that stated that NRC

had issued White findings but again the inspectors had to infer how the findings were

identified. There were no statements in any licensee documentation or as a result of

interviews with licensee management indicating the licensee disagreed with the findings.

The licensee clearly stated the conditions under which the issues were identified. The

inspectors considered the failure to clearly state who identified the issue to be a

weakness for the TDAFWP White finding but not significant enough to leave this item

open. For the TDAFWP White finding, this aspect of IP 95002 is closed. The inspectors

concluded that the licensee failed to clearly document who identified the issue for the

White flooding finding and the CCA and this aspect of IP 95002 was not met.

b. Determine that the Evaluation Documented How Long the Issues Existed and Prior

Opportunities for Identification

The licensees evaluation for the TDAFWP White finding documented that pump to

turbine alignment issues had existed for many years and that each time the pump was

determined to be out of alignment it had been restored to within allowable limits. The

inspectors determined that the licensees evaluation was adequate with respect to

identifying how long the issue existed and prior opportunities for identification.

7

The licensees evaluation for the flooding White finding documented that the change to

the methodology of protecting the site from external lake flooding had been done in

January of 1996. The licensees evaluation also documented some prior missed

opportunities to identify; however, the evaluation failed to address other significant prior

opportunities. As discussed further in various sections of the report, the inspectors

observed that licensee personnel implemented corrective actions that significantly

impacted other license basis events but failed to recognize these impacts. Thus, there

were additional opportunities to identify which were not listed or discussed in the

licensees RCE. The inspectors determined that the licensees evaluation was not

adequate with respect to identifying how long the issue existed and prior opportunities

for identification. This aspect of IP 95002 remains open for the flooding White finding.

c. Determine that the Evaluation Documented the Plant Specific Risk Consequences, As

Applicable, and Compliance Concerns with the Issues Both Individually and Collectively

The risk evaluation performed by the licensee in discussions with the NRC Senior

Reactor Analyst (SRA) prior to issuance of the TDAFWP White finding was not the one

utilized by the licensee for the subsequent RCE. The licensees RCE, stated, in part, In

order to quickly evaluate the safety significance of this issue, the Safety Monitor program

was used by the probabilistic risk assessment (PRA) group. The NRC team did not

understand the need to quickly perform a risk assessment since one had previously

been performed and discussed with an NRC SRA. Nevertheless, the licensee chose to

perform one, but selected a program that did not align with standard NRC significance

determination techniques. The licensees Safety Monitor program is used to monitor on

line risk in a moment to moment manner and use of the program to calculate the risk

consequence for the TDAFWP failure was neither accurate nor appropriate. The team

discussed the licensees risk significance with the NRC SRA who performed the original

assessment and the SRA verified that the licensee had understood and agreed with the

original NRC conclusions. The purpose of this reassessment and write-up was not

understood either by the SRA nor the team. The inspectors also determined that the

licensee had issued a Licensee Event Report for the failure of the TDAFWP and

appropriately entered the failure in the Maintenance Rule database and the Performance

Indicators. Based upon the licensees previous demonstrated knowledge and

understanding of the risk significance of this item, the inspectors concluded that the risk

and compliance portion was weak, but that this fundamental aspect of IP95002 had

been met.

The risk evaluation performed by the licensee for the flooding White finding enforcement

conference was not accepted by the NRC although portions of the licensees

assessment was recognized as acceptable and used to ensure the NRC position was

accurate. Nevertheless, the licensee chose to repeat the previously determined

unsatisfactory risk assessment in the flooding White RCE. In the NRC Final Significance

Determination of a White Finding, dated August 9, 2013, Enclosure 2 provided an

analysis of the licensee risk information. In this analysis the NRC disagreed with the

licensees risk assessment in a number of significant ways, yet these disagreements

appeared to not be factored into the licensees subsequent risk assessment documented

in the associated RCE. The inspectors review of the flooding RCE determined that the

licensee did not address possible compliance concerns or reportability.

8

During interviews, individuals directly involved in responding to the finding cited internal

supplemental calculations, and stated that they believed there would not have been any

consequences to the plant as a result of the finding. Interviewees stated that the

findings risk significance came only from significant conservatisms used in the individual

plant examination external events (IPEEE) evaluation, and not from potential plant

consequences. Interviews with individuals not directly involved in addressing the

flooding finding revealed that working level plant personnel were familiar with the

flooding finding, but their awareness was focused more on the regulatory impacts, with

minimal awareness of potential equipment impacts.

The inspectors concluded that the licensee failed to adequately address the plant

specific risk consequences or compliance concerns related to the flooding White finding

and this aspect of IP 95002 was not met.

d. Findings

No findings were identified.

02.02 Root Cause

a. Determine that the Problem was Evaluated Using a Systematic Methodology to Identify

the Root and Contributing Causes

The inspectors reviewed the licensees RCEs, CCA, and other documents related to the

White findings. The licensee identified a total of four root causes and seven contributing

causes using a systematic methodology. In addition, the licensees CCA identified two

common causes and two contributing causes. The licensee utilized support-refute

matrix, change analysis, barrier analysis, a cause and effects diagram, an event and

causal factor chart, and a why staircase during the two root cause assessments and

the CCA. The inspectors determined that the RCE and CCA were conducted to a level

of detail commensurate with the significance of the issues. The licensees evaluations

included details of each item along with supporting data and other information.

The licensees use of systematic methodology to identify the root and contributing

causes was determined to be adequate for the TDAFWP White finding. Due to the

significant weaknesses identified in the licensees corrective actions, extent of condition,

extent of cause, and root cause, the team concluded that this aspect for the flooding

White finding was negatively impacted. This aspect of IP 95002 will remain open for the

flooding White finding.

b. Determine that the Root Cause Evaluation was Conducted to a Level of Detail

Commensurate with the Significance of the Problem

The licensee utilized the systematic methodologies for the CCA discussed above and

determined that the primary root causes were:

• Less than adequate understanding of the design and licensing basis;

• Corrective Action Program items with incorrect priorities;

• Original construction stress riser introduced to the TDAFWP;

9

• Emergency Preparedness group did not perform reviews of federal guidance;

• A lack of or inadequate leadership; and

• Poor technical procedure quality.

The inspectors noted that while the licensee had poor procedure quality as a root cause

for the TDAFWP issue, the knowledge, skills, and abilities (KSA) of the workers was not

considered as a possible root cause. For example, the TDAFWP alignment procedure

did not require the taking of as-found data nor did the procedure require that if the data

was taken that it be reviewed by engineering personnel. Yet, a qualified maintenance

mechanic would have experience with the need to take such data and would know to

pass it along to their supervisor. The inspectors performed a search of the licensees

CAP database to see if a trend of issues with a cause of KSA existed and did not identify

any trends. The licensees RCEs should have discussed this aspect in sufficient detail

so as to demonstrate that this was not a root cause.

Despite the weakness noted above, the inspectors determined that the RCE for the

TDAFWP White finding was conducted to a level of detail commensurate with the

significance of the issues.

For the flooding White finding and the CCA root cause the inspectors observed that

problems with the quality of condition report evaluations and with Functionality

Assessments (FA) were identified but not included as either a root cause or a

contributing cause. The inspectors also noted that an assessment of the licensees CCA

performed prior to the team arriving on site (Quick Hit PBSA-PBNP-13-03) had a similar

observation and a recommendation to clearly articulate this theme. The inspectors

determined that neither a root cause nor a contributing cause was assigned to either

corrective action program quality or CR evaluations. One CAPR was assigned to

improve the quality of FAs. This is discussed in more detail in Section 02.04, below.

While corrective action program evaluation quality was a part of the issues identified, the

failure of the licensee to either include it as a root cause or to justify why it was not a root

cause was a significant weakness.

The inspectors determined that this aspect of the IP 95002 criteria was not met for the

flooding White finding and the CCA.

c. Determine that the Root Cause Evaluation Included a Consideration of Prior

Occurrences of the Problem and Knowledge of Prior Operating Experience

The inspectors determined that the licensees evaluation included a consideration of

prior occurrences of the issues and industry operating experience. The RCE for the

TDAFWP determined that a prior opportunity was missed in early 2011 during the Unit 2

refueling outage when pipe stresses were identified on the opposite unit TDAFWP. The

licensee determined that even though the pipe stresses were identified and corrected

that a CR was not issued and thus the opportunity to apply this information to the next

Unit 1 refueling outage and TDAFWP maintenance activity was missed.

The inspectors concluded that the root cause evaluation included a review of prior and

precursor problems and properly evaluated internal and industry operating experience.

This aspect of the IP 95002 criteria was met for the TDAFWP finding.

10

The RCE for the White flooding finding determined that prior opportunities were missed

to properly correct the deficiency. This included opportunities in 2004, when condition

reports were generated questioning the adequacy of the wave run-up barriers, given the

1996 procedure change. This also included opportunities in 2012 where a functionality

assessment inappropriately contained conclusions regarding the functionality of the

wave barriers on perceived risk. The inspectors noted that these opportunities were

factored into the determination of one of the root causes. The inspectors also noted the

RCE discussion on industry OE and noted several instances where the causes of

industry deficiencies were similar to the causal factors identified for the White flooding

issue

As discussed later in this inspection report unintended consequences were introduced

during the corrective actions to the White flooding finding. The failure to recognize these

consequences represented additional occurrences of the problem. The inspectors

determined that this aspect of the IP 95002 criteria was not met for the flooding White

finding and the CCA.

d. Determine that the Root Cause Evaluation Addresses the Extent of Condition and the

Extent of Cause of the Problem

The licensees RCE included an evaluation of the extent of condition and extent of cause

of the issues. The inspectors determined that the RCE for the TDAFWP issue was

adequate with comments. These comments are discussed in section 02.04 of this

report. The inspectors also noted that during an assessment of the licensees RCE that

was performed prior to the team arriving on site (Quick Hit PBSA-PBNP-13-03) that

deficiencies with the TDAFWP had been identified. For example, the extent of condition

prior to the Quick Hit was limited to rotating couplings of the same make and model as

that which had failed on the Unit 1 TDAFWP. Following a recommendation of the Quick

Hit team, the licensee had expanded the extent of condition to include other make and

model couplings as well as all rotating connections. Based on a review of the RCE and

CCA and discussions with licensee management and staff personnel, the inspectors

concluded that the evaluations for the TDAFWP White finding adequately addressed the

extent of condition and the extent of cause. This aspect of the IP 95002 was not for the

TDAFWP finding.

The inspectors determined that the RCE for the flooding White finding also included an

evaluation of the extent of condition and extent of cause but based on the NRC findings

documented in Section 02.04 of this report the inspectors concluded that this item was

not acceptable. For example, the RCE did not consider possible bypass paths around

the external flooding barrier. During field walk downs, the inspectors identified two

different drain pipes in the concrete near the CWPH which directly communicated with

the lake shore and should have been evaluated as possible bypass paths. The

inspectors concluded that the evaluations for the flooding White finding did not satisfy

this aspect of the IP 95002 criteria.

e. Findings

No findings were identified.

11

02.03 Corrective Actions

a. Determine that Appropriate Corrective Actions are Specified for Each Root and

Contributing Cause or that the Licensee has an Adequate Evaluation for Why No

Corrective Actions are Necessary

The inspectors assessed the corrective actions for the RCEs and the CCA. The

inspectors verified that all root causes had associated CAPRs and that all contributing

causes had associated corrective actions. The inspectors then performed a more

detailed assessment of selected CAPRs and corrective actions. The detailed

assessment included a sample of corrective action program documents, field walk

downs, interviews with selected licensee individuals, and reviews of the design and

licensing basis.

The inspectors concluded that the corrective actions for the TDAFWP finding were

vague and needed additional clarification. As previously noted, the scope of the root

cause was narrowly focused but this had previously been identified by an internal

licensee review. As a result, the scope of the corrective actions had been expanded to

include other rotating equipment connections. Additional corrective actions were

reviewed by the inspectors with no further substantive observations. The inspectors

concluded that the CAPRs and corrective actions for the TDAFWP met the requirements

of IP 95002.

During the reviews of the corrective action program documents, the inspectors noted

that the licensee questioned whether the installation of the flood protection barriers had

introduced unintended consequences. Specifically, the corrective action to install a

more robust wave barrier in lieu of sandbagging efforts failed to restore compliance with

the CLB. While the improved wave barriers provided necessary protection against wave

action, they introduced unrecognized hazards during the probable maximum

precipitation and turbine building internal flooding events. These barriers blocked

natural drainage paths credited for flood relief and rendered these paths nonfunctional

as a result of wave barrier installation. The inspectors noted that this issue was not

recognized by the licensee until November 2013 for one of the flooding events, and

January 2014 for the other event, and thus, the licensees interim corrective actions for

the flooding finding were deficient between March and November 2013 due to procedure

call-up PC 80 Part 7, which remained inadequate during this time. As a result, the

licensee was required to add compensatory actions during wave barrier installation to

provide additional flow paths by opening the CWPH roll-up doors.

When developing the compensatory action to address the deficiency associated with the

new wave barriers, the licensee failed to recognize that the new compensatory

measures required actions outside of the CLB. Specifically, Section 2.5 Hydrology in

the FSAR for the Maximum precipitation flood states, in part, that the topography of

the site results in adequate natural drainage to remove this amount of water and limit

ponding depth to prevent adversely affecting safety related equipment. The

nonfunctional drainage paths following wave barrier installation resulted in the licensee

having to identify an alternate path for flood water drainage flow. As a compensatory

action, the licensee chose to open the CWPH roll-up doors, route flood waters through

the CWPH, and relying on internal flood relief dampers to open and drain the water. The

licensee viewed those compensatory actions as still with its CLB. As a result, the

12

inspectors determined that the licensee failed to properly screen the actions as

compensatory measures under the requirements of 10 CFR 50.59.

The inspectors noted that as a result of the failure to evaluate these actions under

10 CFR 50.59, the licensee did not properly consider several factors associated with the

compensatory actions that should have been evaluated. Some of these factors included

flood water flow rates through the open doors, the impact of debris and slush from

outside being carried into the CWPH and clogging the flood relief dampers, the impact of

the cold temperatures on the equipment in the rooms during the potentially extended

periods of time during which the doors could be open, and security impacts.

In addition, the inspectors noted the licensee failed to recognize that procedure

PC 80 Part 7, failed to account for the time necessary to ensure that the barriers would

be constructed before the lake reached conditions where deep wave action could impact

the site. Specifically, the licensees calculation specified that 8.2 weeks would be

available after Procedure PC 80 Part 7, initiated actions to install the wave barriers

based on lake level.

The inspectors reviewed EC 279455, Time Available to Respond to Threat From Rising

Water, and the licensees lake level determination monthly surveillance, PBF-2124,

PPCS Forebay and Pump Bay Level Alarm Setpoints, and identified several

deficiencies. These deficiencies included non-conservative assumptions when using the

maximum monthly rate of lake level rise, non-conservative assumptions for the lake level

at which the site could be impacted by the waves, a non-conservative allowance to rely

on the previous months data if no lake level data was immediately available, and an

error in an assumption that wave barriers would be installed earlier than PC 80 Part 7,

actually required. When the licensee corrected these inputs, the inspectors noted that

the time available for action was significantly reduced to less than three weeks.

The inspectors observed that PC 80 Part 7, granted three weeks allowance for activities

to be scheduled and performed to install the wave barriers. The inspectors concluded

that the deficiencies in the licensees timelines left them vulnerable in that actions may

not have been initiated soon enough to protect the site from the wave run-up design

basis event. The inspectors determined that this aspect of IP 95002 was not met for the

flooding White finding.

b. Determine that the Corrective Actions Have Been Prioritized with Consideration of Risk-

Significance and Regulatory Compliance

The inspectors assessed the licensees timeliness of corrective actions for the RCEs and

CCA associated with the risk significant issues. The inspectors noted that there were no

formal tracking mechanisms or documentation for several of the corrective actions that

had been previously taken prior to the completion of the RCEs and CCA. Formalized

tracking measures would assure the actions are satisfactorily completed and allow for

documentation of the basis for closure.

The inspectors concluded that an appropriate schedule had been established for

implementing and completing the corrective actions for the TDAFWP White finding. This

aspect for the flooding White finding will remain open pending the inspectors review of

the additional corrective actions the licensee will need to perform.

13

c. Determine that a Schedule has been Established for Implementing and Completing the

Corrective Actions

As discussed in Section 02.03.b, above, the inspectors determined that the licensee had

established an appropriate schedule for implementing the corrective actions for the

TDAFWP White finding. The aspect for the flooding White finding will remain open

pending the inspectors review of the additional corrective actions that the licensee will

need to perform.

d. Determine that Quantitative or Qualitative Measures of Success Have Been Developed

for Determining the Effectiveness of the Corrective Actions to Prevent Recurrence

The inspectors review of the effectiveness review (EFR) plan identified a number of

weaknesses. The inspectors determined that these weaknesses rose to the level of a

finding and that the weaknesses were broad and deep enough to conclude that this

section did not meet the requirements of IP 95002. As the TDAFWP finding occurred

first and there had been additional time the EFR had already been substantially

performed for this issue. The interim assessments, combined with the general quality of

the RCE led the inspectors to conclude that this section is complete for the TDAFWP

finding but remains open for the flooding White finding and the CCA.

e. Determine that the Corrective Actions Planned or Taken Adequately Address a Notice of

Violation that was the Basis for the Supplemental Inspection, if Applicable

For the TDAFWP White finding, the licensee did not respond to the initial NOV because

the corrective actions taken and planned to be taken to correct the violation, and the

date when full compliance was achieved was already addressed on the docket in NRC

Inspection Report 05000266/2012009. As part of the 95002 inspection, the team

members performed a sampling of the immediate corrective actions and determined the

full compliance had been restored. The team considered that the IP 95002 requirements

were met for the TDAFWP White finding.

For the flooding White finding, the licensee did not respond to the initial NOV because

the corrective actions taken and planned to be taken to correct the violation, and the

date when full compliance was achieved was already addressed on the docket in

NRC Inspection Report 05000266/2013002 and 05000301/2013002 and in the

licensees submittals dated July 10, 15, and 29, 2013. As part of the 95002 inspection,

the team members performed a sampling of the immediate corrective actions and

determined the full compliance had been restored. However, as stated above, the

inspectors noted that the corrective actions resulted in unintended consequences. In

addition, as noted previously, the inspectors identified a deficiency where insufficient

corrective action was taken to correct PC 80 Part 7, in order to preclude repetition of the

original significant condition adverse to quality. Thus the team concluded that the

requirements of IP 95002 were not met for the flooding White finding.

f. Findings

(1) Failure to Take Corrective Actions to Address External Flooding Procedure Deficiencies

Introduction: The inspectors identified a finding of very low safety significance and an

associated non-citied violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective

14

Actions, in that from March 13, 2013 until February 14, 2014, the licensee failed to

assure that for a significant condition adverse to quality (SCAQ), the cause of the

condition was determined and corrective actions were taken to preclude repetition.

Specifically, the licensees corrective actions failed to preclude repetition of an SCAQ

where Procedure PC 80 Part 7, Lake Water Level Determination, as implemented,

would not protect safety-related equipment in the turbine building or CWPH. After the

licensee had taken corrective actions to improve the wave barrier procedure in response

to an NRC-identified NOV, PC 80 Part 7, and other flood protection implementing

procedures specified inadequate timelines to ensure wave run-up flood barriers would

be installed prior to the lake level at which wave run-up could impact the site.

Description: The inspectors reviewed procedures associated with flooding as part of

their independent extent of condition and extent of cause, and review of corrective

actions to prevent recurrence. The inspectors noted the licensee failed to recognize that

procedure, PC 80 Part 7, did not grant adequate timelines to ensure that the barriers

would be constructed before the lake reached conditions where deep wave action could

impact the site. Specifically, the licensees calculation specified that 8.2 weeks would be

available after Procedure PC 80 Part 7, initiated actions to install the wave barriers

based on lake level. The inspectors observed that based on these timelines,

PC 80 Part 7 granted three weeks allowance for activities to be scheduled and

performed to install the wave barriers. Specifically, PC 80 Part 7, stated, in part,

IF corrected mean level is greater than or equal to +0.5 ft., THEN PERFORM the

following: NOTIFY maintenance to generate on demand PM (PMRQ 00059608-02) to

INSTALL barriers and sandbags as required to be completed within three weeks.

The inspectors reviewed EC 279455, Time Available to Respond to Threat From Rising

Water, and the licensees lake level determination monthly surveillance, PBF-2124,

PPCS Forebay and Pump Bay Level Alarm Setpoints, and found several deficiencies.

These deficiencies included non-conservative assumptions when using the maximum

monthly rate of lake level rise, non-conservative assumptions for the lake level at which

the site could be impacted by the waves, non-conservative allowances to rely on the

previous months data if no lake level data was immediately available, and an error in an

assumption that wave barriers would be installed earlier than PC 80 Part 7 actually

dictated. Inspectors noted that the procedure had no barriers to prevent the previous

months data from being used during multiple subsequent months. When the licensee

corrected these inputs, the inspectors noted that the time available to fully implement the

provisions of PC 80 Part 7 significantly reduced to less than the three weeks called for in

the procedure.

The inspectors concluded that these deficiencies in the licensees timelines left them

vulnerable in that actions may not be initiated soon enough to protect the site from the

wave run-up design basis event. The inspectors noted that these deficiencies

represented a failure of the licensees corrective action to preclude repetition of an

SQAC where Procedure PC 80 Part 7, Lake Water Level Determination, as

implemented, would not protect safety-related equipment in the turbine building or

CWPH.

In addition, to the PC 80 Part 7 issues associated with the timelines for barrier

installation, the inspectors found additional procedural deficiencies that should have

been identified and corrected as part of the corrective actions taken to address the

flooding NOV. PC 80 Part 7 procedural deficiencies included error traps where steps

15

could be performed out of sequence (i.e. barriers installed before CWPH doors open),

and a failure to include CWPH doors in robust tag-out process to ensure their open

position was controlled. PBF-2124 procedural inadequacies included direction to install

jersey barriers rather than the more robust barriers associated with the licensees RCE

corrective actions. Inspectors noted that this reference to the jersey barriers referred to

the previous wave run-up flooding response strategy. The inspectors identified that the

same +0.5ft. installation threshold error was made in PBF-2124, as well as the licensees

external flooding abnormal procedure, AOP 13C.

Licensee procedure PI-AA-204, Condition Identification and Screening Process,

Section 2.45 defines a Significant Condition Adverse to Quality (SCAQ) as, Failures,

malfunctions, deficiencies, deviations, defective items, abnormal occurrences, non-

conformances, or out-of control processes that significantly threatens or has

compromised nuclear safety or radiological safety, as well as any significant reportable

industrial safety or environmental (e.g., OSHA, State, etc.) issues. SCAQ issues require

corrective actions to prevent recurrence. Condition Report 01883633 identified the

White flooding finding and associated performance deficiency as an SQAC.

The inspectors also noted that the licensee completed an interim action to improve the

wave barrier and associated procedure on March 13, 2013, and a final corrective action

CAPR 01883633-22 on November 30, 2013 to implement a plant modification to

strengthen the physical external flood protection measures associated with a high lake

level wave run-up and associated procedure guidance and design documentation. The

inspectors observed that this action was credited in the licensees RCE as an action to

prevent recurrence of the original SQAC. As a result, the inspectors determined that the

licensee failed to take corrective actions to preclude repetition of an SCAQ where

Procedure PC 80 Part 7, as implemented, would not protect safety-related equipment in

the turbine building or CWPH.

Analysis: The inspectors determined that the licensees failure to take corrective actions

to address the inadequate flooding procedure was a performance deficiency, because it

was the result of the failure to meet the requirements of 10 CFR Part 50, Appendix B,

Criterion XVI; the cause was reasonably within the licensees ability to foresee and

correct; and it should have been prevented. The inspectors determined that the finding

had a cross-cutting aspect in the area of problem identification and resolution, because

the licensee failed to thoroughly evaluate issues to ensure that resolutions address

causes and extents of condition commensurate with their safety significance (P.2).

Specifically, the licensee failed to fully evaluate issues with the flooding procedure to

ensure the corrective actions they took would assure that robust protection from wave

run-up would be installed prior to reaching a lake level where deep wave action could

present a threat to the site.

The inspectors screened the performance deficiency in accordance with IMC 0612,

Power Reactor Inspection Reports, Appendix B, and determined that the issue was

more than minor because the finding was associated with the Mitigating Systems

Cornerstone attributes of Protection Against External Factors (Flood Hazard) and

Procedure Quality, and adversely affected the cornerstone objective to ensure the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences (i.e. core damage). Specifically, the licensees

failure to procedurally control external flooding design features, to ensure they would not

adversely affect the strategy for other flooding events, could negatively impact mitigating

16

systems ability to respond during an external flooding event. The inspectors evaluated

the finding using IMC 0609, Attachment 0609.04, Tables 2 and 3, and Appendix A.

Based on a review of Appendix A, Exhibit 2, Item 4.B, the inspectors determined that this

issue screened as having Very low safety significance (Green).

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions,"

requires, in part, that Measures shall be established to assure that conditions adverse

to quality, such as failures, malfunctions, deficiencies, deviations, defective material and

equipment, and non-conformances are promptly identified and corrected. In the case of

significant conditions adverse to quality, the measures shall assure that the cause of the

condition is determined and corrective action taken to preclude repetition. Contrary to

this requirement, from March 13, 2013 until February 14, 2014, the licensee failed to

assure that for a significant condition adverse to quality, the cause of the condition was

determined and corrective actions were taken to preclude repetition. Specifically, the

licensees corrective actions failed to preclude repetition of an SCAQ where Procedure

PC 80 Part 7, Lake Water Level Determination, as implemented, would not protect

safety-related equipment in the turbine building or CWPH. After the licensee had taken

corrective actions to improve the wave barrier procedure in response to an NRC-

identified NOV, PC 80 Part 7 and other flood protection implementing procedures

specified inadequate timelines to ensure wave run-up flood barriers would be installed

prior to the lake level at which wave run-up could impact the site. Specifically, the

licensee completed an interim action to improve the wave barrier and associated

procedure on March 13, 2013, and a final corrective action CAPR 01883633-22 on

November 30, 2013, to implement a plant modification to strengthen the physical

external flood protection measures associated with a high lake level wave run-up and

associated procedure guidance and design documentation. These actions failed to

preclude repetition of the original SCAQ. Corrective actions for this issue included

changing the affected procedures to install the wave barriers at a lower lake level,

changing the lake level determination surveillance from monthly to weekly, and reducing

the allowed installation time for the barriers from 3 weeks to 1 week. Because the

violation was of very low safety significance and was entered into the licensees

corrective action program (CR 01940739), this violation is being treated as an NCV,

consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000266/2014007-01; 05000301/2014007-01; Failure to Take Corrective

Actions to Address External Flooding Procedure Deficiencies)

(2) Failure to Maintain External Flooding Procedure to Address All Possible CLB Floods

Introduction: The inspectors identified a finding of very low safety significance and

associated non-citied violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, in that from January 19, 1996 until November 25, 2013, the

licensee failed to ensure that activities affecting quality were prescribed by documented

procedures of a type appropriate to the circumstances to address external flooding as

described in the Final Safety Analysis Report (FSAR). Specifically, PC 80 Part 7, Lake

Water Level Determination directed advanced installation of concrete barriers to protect

against deep wave action from the lake, which introduced significant unrecognized

blockages in the natural drainage path credited in the FSAR to protect against the

probable maximum precipitation and Turbine Building internal flooding events.

17

Description: The inspectors reviewed the licensees procedures and corrective action

documents and noted an important deficiency associated with procedure PC 80 Part 7.

Specifically, CR 01932698, 95002 Wave run-up protection may conflict with other

floods, was generated a few days prior to the 95002 inspection teams arrival onsite.

This condition report described the concern that while wave barriers were installed near

the CWPH, the probable maximum precipitation and turbine building flooding events

could result in several feet of water at the CWPH and turbine building rollup doors due to

the wave barriers blocking natural site drainage paths. The inspectors noted that this

deficiency traced back to the original inappropriate action cited in the White Flooding

finding, where in 1996, the licensee inappropriately deleted an AOP directing use of

sandbags at plant doorways and substituted a wave barrier installation strategy without

recognizing the adverse impacts of the change.

The inspectors noted that the immediate corrective actions for the Flooding Apparent

Violation that were taken in March 2013 to improve the wave barrier described in

PC 80 Part 7, failed to address all deficiencies that were created when sand bagging

actions were changed to wave barrier installation in 1996. While the improved wave

barriers provided necessary protection against wave action, they failed to address

unrecognized hazards during the probable maximum precipitation and turbine building

internal flooding events. These barriers blocked natural drainage paths credited for flood

relief and rendered these paths nonfunctional as a result of wave barrier installation.

The Inspectors determined that procedure PC 80 Part 7 was inadequate until actions

were taken to modify it to provide additional flow paths for flood relief. The inspectors

noted that this issue was not recognized by the licensee until November 2013 for the

turbine building flooding event, and late January 2014 for the PMP event.

The inspectors concluded that the licensee did not adequately address the flooding

finding barrier deficiencies described in the original white flooding finding. This was

evident in the licensees interim corrective actions taken in March 2013, when the

licensee failed to restore full compliance, and did not recognize the need for providing an

additional drainage path. However, the inspectors noted that the licensee had not

implemented final corrective actions for wave barrier modification and flooding procedure

changes until November 2013, at which point steps were added to PC 80 Part 7 that

created a compensatory drainage path. As a result, the inspectors concluded that the

issue was most appropriately characterized as a failure to ensure that activities affecting

quality were prescribed by documented procedures of a type appropriate to the

circumstances to address external flooding in accordance with 10 CFR 50 Appendix B,

Criterion V. The inspectors also noted that this issue should have been readily identified

as a direct outcome of reviewing the NRC-identified finding, and it was not the result of a

thorough RCE which resulted in hidden issues surfacing.

Analysis: The inspectors determined that the licensees failure to maintain an external

flooding procedure appropriate to the circumstances to ensure the site was not

adversely impacted during CLB flooding events was a performance deficiency, because

it was the result of the failure to meet the requirements of 10 CFR Part 50, Appendix B,

Criterion V; the cause was reasonably within the licensees ability to foresee and correct;

and it should have been prevented. The inspectors determined that the finding has a

cross-cutting aspect in the area of problem identification and resolution, because the

licensee failed to take effective corrective actions to address issues in a timely manner

commensurate with their safety significance (P.3). Specifically, licensee personnel failed

to take appropriate interim corrective actions in March of 2013 when correcting a SCAQ

18

in that the interim action plan posed additional hazards to the site during design basis

floods.

The inspectors screened the performance deficiency in accordance with IMC 0612,

Power Reactor Inspection Reports, Appendix B, and determined that the issue was

more than minor because the finding was associated with the Mitigating Systems

Cornerstone attributes of Protection Against External Factors (Flood Hazard) and

Procedure Quality, and adversely affected the cornerstone objective to ensure the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences (i.e. core damage). Specifically, the licensees

failure to procedurally control external flooding design features to ensure they would not

adversely affect the strategy for other flooding events, could negatively impact mitigating

systems ability to respond during external and internal flooding events.

The inspectors evaluated the finding in accordance with IMC 0609, Significance

Determination Process, Attachment 0609.04, Initial Characterization of Findings. The

inspectors determined that the finding affected the Mitigating Systems Cornerstone and

evaluated the finding using Appendix A, The Significance Determination Process for

Findings At-Power, Exhibit 2, for the Mitigating Systems Cornerstone. In the Mitigating

Systems Cornerstone, the inspectors answered "Yes" to the screening question Does

the finding represent a loss of system and/or function? because an assumed turbine

building (TB) internal flooding event in a condition with the jersey barriers installed due to

high lake water level could ultimately result in the loss of emergency diesel generators

and other safety-related equipment. Therefore, the finding required a detailed risk

evaluation.

The probability of the jersey barriers being installed was evaluated based on the fact that

the jersey barriers have not been installed during the 18 years (since 1996) that the

jersey barriers were available for installation if high lake water level was encountered.

Using a statistical Bayesian update with a Jeffreys non-informative prior, the probability

that the jersey barriers could have been installed was determined to be 2.63E-2.

The risk evaluation was performed by Region III Senior Reactor Analysts (SRAs). The

increase in core damage frequency (CDF) was calculated assuming scenarios

involving internal turbine building flooding events. The exposure time assumed was one

year which is the maximum allowed by the significance determination process.

For the evaluation of the risk significance, the SRAs considered TB flooding events with

three plant systems that have basically an unlimited system volume if the flooding event

is not terminated. These systems are the fire protection (FP) system, the circulating

water (CW) system, and the service water (SW) system.

To evaluate this finding, the Senior Reactor Analysts (SRAs) determined the frequency

of a pipe break (or expansion joint failure) using Electric Power Research Institute

(EPRI) Report 302000079, Pipe Rupture Frequencies for Internal Flooding Probabilistic

Risk Assessments, Revision 3. The pipe breaks of interest were determined to be

those between approximately 20,000 gpm and 36,000 gpm. The lower value of

20,000 gpm is based on the drainage capacity at the eight foot level (which is the ground

floor elevation in the TB) provided by a combination of gaps in the metal siding of the

circulating water pump house (CWPH) walkway and the storm drains still available even

with the jersey barriers installed. Pipe breaks of less than 20,000 gpm would not result

19

in water accumulation on the lowest level of the TB and thus would not imperil risk

significant equipment. The upper value of 36,000 gpm is based on calculation

2008-0024, Auxiliary Feedwater Pump Room Flood, which determined that for a

36,000 gpm TB flood rate, the TB rollup door(s) would fail at a level of 18 inches and

allow a flow of up to 36,000 gpm while maintaining the TB flood level at less than

18 inches. For the risk evaluation, a maximum TB flood rate of 36,000 gpm was thus

used to represent the delta risk associated with the finding, since this is the maximum

drainage flow through the failed TB rollup door(s). Any TB flood rate greater than

36,000 gpm would cause the TB water level to exceed 18 inches if the break flow was

not immediately terminated regardless of whether the jersey barriers were installed or

not. It was conservatively assumed that exceeding 18 inches level in the TB would

result in a core damage event (i.e., a conditional core damage probability (CCDP) of 1.0)

due to the loss of risk significant plant equipment.

Fire Protection System

The FP system was screened because of the relatively low maximum flood rates that

can occur with a break in the FP system. The capacity of the two fire water pumps

together is approximately 6,800 gpm, which is well below the drainage capacity of

approximately 20,000 gpm at the eight foot level.

Circulating Water System

The SRAs evaluated the delta risk associated with a break in the Circulating Water (CW)

system with the jersey barriers installed. Two different failure causes were available on

the CW system which could result in a break of greater than 20,000 gpm: (1) a CW

system expansion joint (EJ) failure, or (2) a CW system piping break. Each of these

failures was evaluated separately.

Circulating Water System Expansion Joints

In the EPRI report, the failure rate of an EJ per year was given for flood rates greater

than 10,000 gpm. This value was conservatively used to represent the failure rate of an

EJ for a flood greater than 20,000 gpm (i.e., a flood rate that would exceed the drainage

capacity at the eight foot level). There are eight EJs on the CW system in the TB. From

the EPRI report, the frequency of a major flood with from a CW system EJ with a flood

rate of greater than 10,000 gpm is 6.08E-6/yr/EJ. With eight EJs per Unit, the frequency

of an EJ failure is 4.86E-5/yr.

Without the jersey barriers installed, the flood water would drain out toward the CWPH

and down towards the lake with an essentially open path (i.e., essentially an unlimited

drainage rate outside the TB). With the jersey barriers installed, the drainage capacity

would be approximately 20,000 gpm at the eight foot level provided by a combination of

gaps in the metal siding of the CWPH walkway and the storm drains near the CWPH.

The drainage capacity provided by the gaps in the metal siding of the CWPH walkway

would increase as the height of the water level outside the Turbine Building increased

and would represent the majority of the drainage flow above the eight foot level. Using

the TB floor volume, the outside volume up to the jersey barriers, and the drainage rate

outside the TB (as a function of height), the licensee estimated that there was

approximately 31 minutes available to secure the CW pumps to terminate the break flow

20

before exceeding a level of 18 inches in the TB. A CW system flooding event would

require the operators to enter AOP-13A, Circulating Water System Malfunction.

Securing the CW pumps on a CW system flood event is Step 1 of the AOP. The SRAs

used the SPAR-H method (per NUREG/CR-6883) to calculate a human error probability

(HEP) for the failure of the operators to terminate a CW flood event. Using SPAR-H an

HEP for the failure of the operators to secure the CW pumps before exceeding 18 inches

level in the TB was calculated to be 0.2. This calculation assumed high stress for both

diagnosis and action and poor ergonomics for diagnosis (since a local operator would be

required to identify the flood location).

Using an HEP value of 0.2 for the probability that the operators would secure the CW

pumps before exceeding 18 inches in the TB, and the probability of 2.63E-2 that the

jersey barriers would be installed, the result was a delta core damage frequency (CDF)

of 2.56E-7/yr for an event involving a CW expansion joint failure in the turbine building.

Circulating Water System Pipe Breaks

To evaluate the CDF for CW system piping breaks, the length of large diameter CW

piping in the TB (obtained from the Point Beach PRA 7.1, Internal Flooding Notebook)

was used. For the CW piping random failure event, the frequency of a major flooding

event was conservatively estimated to be 7.95E-7/yr/ft, from the EPRI report. This is the

failure rate based on a flood rate of greater than 2000 gpm and was conservatively used

to represent the failure rate of a flood greater than 20,000 gpm. Based on this piping

failure rate per unit length and the lengths of CW piping obtained from the Point Beach

PRA 7.1, Internal Flooding Notebook, the frequency of a major flood event in the TB due

to a random CW pipe failure was evaluated to be 2.39E-5/yr. Using an HEP of 0.2

(as described above) for the failure of the operators to secure the CW pumps before

exceeding 18 inches level in the TB, and the probability of 2.63E-2 that the jersey

barriers would be installed, the result was a CDF of 1.25E-7/yr. for an event involving a

random CW system piping failure in the turbine building.

Service Water System Pipe Breaks

To evaluate the CDF for SW system piping breaks, the length of large diameter

(greater than 4 inches) SW piping in the TB was obtained from the Point Beach

PRA 7.1, Internal Flooding Notebook. From the EPRI report, a failure rate of

3.57E-7/yr/ft. was obtained for SW piping with a diameter between 4 and 10 inches,

and a failure rate of 6.44E-8/yr/ft. was obtained for SW piping with a diameter greater

than 10 inches. The length of SW piping in the TB with a diameter between 4 and

10 inches, and the length of SW piping in the TB with a diameter of greater than

10 inches was obtained from the Point Beach PRA 7.1, Internal Flooding Notebook.

The piping failure rate for a major flood event in the EPRI report is based on a flood rate

of greater than 2000 gpm. This failure rate was conservatively used to represent the

failure rate of a flood greater than 20,000 gpm. Based on these piping failure rates per

unit length and the lengths of SW piping obtained from the Point Beach PRA 7.1,

Internal Flooding Notebook, the frequency of a flood event in the TB due to a random

SW pipe failure was evaluated to be 4.40E-4/yr.

21

The pipe breaks of interest for the SW system were determined to be those between

approximately 20,000 gpm and 27,000 gpm. The lower value of 20,000 gpm is based as

stated before on the drainage capacity at the eight foot level. The upper value of 27,000

gpm is based on the flow rate for three SW pumps at run-out flow per the Point Beach

PRA 7.1, Internal Flooding Notebook. Based on a maximum SW break of 27,000 gpm,

the maximum TB flood level would be approximately 14 inches. This level would

correspond to the steady-state level at which the drainage capacity outside provided by

the gaps in the metal siding of the CWPH walkway and the storm drains near the CWPH

would equal the assumed 27,000 gpm flood rate.

The Point Beach Standardized Plant Analysis Risk (SPAR) model version 8.22 and

Systems Analysis Programs for Hands on Integrated Reliability Evaluations version

8.0.9.0 software was used to obtain a delta Conditional Core Damage Probability

(CCDP) for the event. A loss of service water (LOSW) initiating event was assumed.

Using the licensees evaluation of equipment that is lost as a function of level, all

equipment in the TB that would be submerged at or below 17 inches was assumed to fail

to bound failure of equipment at 14 inches. The 1P53 Auxiliary Feedwater Pump was

also assumed to fail as a surrogate to represent the loss of the power supply for the

Unit 2 motor-driven AFW pump 2P53 during a Unit 2 flooding event because the SPAR

model replicates Unit 1. The result was a CCDP of 1.68E-2.

Based on the probability of 2.63E-2 that the jersey barriers would be installed, and the

CCDP of 1.68E-2 for an event if the jersey barriers were installed, the result was a

CDF of 1.94E-7/yr. for an event involving a random SW system piping failure in the

turbine building.

Total CDF for Internal Events

The total CDF for internal events caused by random failures of piping and CW

expansion joints is the sum of the individual delta risk values or 5.76E-7/yr.

External Event Risk Contribution

Since the resultant internal event CDF is greater than 1.0E-7/yr., an evaluation of

external event contributions was obtained. Due to the nature of the performance

deficiency, no fire-induced floods were credible. However, a seismic-induced flooding

event was considered. Using guidance from NRCs Risk Assessment Standardization

Project (RASP) handbook, only the Bin 2 seismic events were assumed to represent a

CDF. Bin 2 was defined in the RASP handbook as seismic events with intensities

greater than 0.3g, but less than 0.5g. Earthquakes of lesser severity are unlikely to

result in large pipe failures and earthquakes of a larger magnitude could result in major

structural damage throughout the plant, which would not be representative of a

differential risk. The initiating event frequency of an earthquake in Bin 2 for

Point Beach was estimated to be 1.3E-5/yr. using Table 4A 1 of Section 4 of the RASP

handbook.

To estimate the seismic capacity of the CW piping and the CW EJs, an evaluation of the

seismic capacity for a similar Westinghouse plant was referenced. For this plant, it

stated that the CW piping and the CW EJs had high seismic capacity, and a flooding

assessment due to seismic concerns was screened from the assessment.

22

For the SW piping in the TB, making the conservative assumption that the high

confidence of low probability of failure (HCLPF) capacity for the SW piping is 0.3g, a

failure probability of 3.9E-2 was obtained for the SW system. It was conservatively

assumed that every SW system piping failure resulted in the maximum flooding rate of

27,000 gpm. Similar to the earlier evaluation of random SW piping failure due to internal

events, the licensees evaluation of equipment that is lost as a function of level was

used. All equipment in the TB with a flood level of less than or equal to 17 inches was

assumed to fail. The 1P53 Auxiliary Feedwater Pump was also assumed to fail as

discussed earlier. A dual unit loss of offsite power (LOOP) initiating event was assumed

to occur as a result of the seismic event, and it was conservatively assumed that the

operators would fail to recover off-site power for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Also, the SW pumps

were assumed to fail-to-run. The result was a CCDP of 0.37. The CDF for a seismic

event was estimated to be 1.84E-7/yr.

Total CDF For This Issue

The total CDF associated with the finding was obtained as the sum of the CDF for the

internal events random failures of piping and CW expansion joints, and the CDF for a

seismic event or 7.6E-7/yr. The dominant sequence was associated with a random

CW system expansion joint failure in the TB that results in flooding that renders risk

significant equipment unavailable.

Large Early Release Frequency Risk Contribution

Since the total estimated change in core damage frequency was greater than 1.0E-7/yr.,

IMC 0609 Appendix H, Containment Integrity Significance Determination Process was

used to determine the potential risk contribution due to large early release frequency

(LERF). Point Beach is a 2-loop Westinghouse Pressurized Water Reactor (PWR) with

a large dry containment. Sequences important to LERF include steam generator tube

rupture events and inter-system loss-of-coolant-accident (LOCA) events. These were

not the dominant core damage sequences for this finding.

Therefore, based on the detailed risk evaluation, the SRAs determined that the finding

was of very low safety significance (Green).

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures,

and Drawings," requires, in part, that activities affecting quality shall be prescribed by

documented instructions, procedures, or drawings, of a type appropriate to the

circumstances and shall be accomplished in accordance with these instructions,

procedures, or drawings. Contrary to this requirement, from January 19, 1996 until

November 25, 2013, the licensee failed to ensure that activities affecting quality were

prescribed by documented procedures of a type appropriate to the circumstances to

address external flooding as described in the FSAR. Specifically, PC 80 Part 7, Lake

Water Level Determination directed advanced installation of concrete barriers to protect

against deep wave action from the lake, which introduced significant unrecognized

blockages in the natural drainage path credited in the FSAR to protect against the

probable maximum precipitation and Turbine Building internal flooding event. Corrective

actions for this issue included changing the procedure and FSAR to include actions to

provide an additional flood relief path through the CWPH building and reliance on

internal flood relief dampers for the affected flooding events. Because the violation was

23

of very low safety significance and was entered into the licensees corrective action

program (CR 01932698), this violation is being treated as an NCV, consistent with

Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000266/2014007-02;

05000301/2014007-02; Failure to Maintain External Flooding Procedure to Address

All Possible CLB Floods)

(3) Failure to Perform a Required 10 CFR 50.59 Evaluation

Introduction: The inspectors identified a finding of very low safety significance and

associated Severity Level IV, non-citied violation, of 10 CFR 50.59(d)(1), Changes,

tests and experiments, when, on November 25, 2013, the licensee failed to perform an

evaluation against the criteria in 10 CFR 50.59(c)(2) for a change to procedure

PC 80 Part 7 to include actions to maintain functionality of drainage paths during

probable maximum precipitation and turbine building flooding events. Specifically,

PC 80 Part 7, Lake Water Level Determination was changed to include actions to open

the CWPH rollup doors to provide an additional drainage path while wave barriers were

in place, without evaluating the viability of reliance on additional flood features not

credited for external flooding in the CLB.

Description: When developing the procedural actions to address the deficiency

associated with the new wave barriers, the licensee failed to recognize that these

actions were outside the CLB. Specifically, procedure PC 80 Part 7 was revised on

November 25, 2013 to include direction to ENSURE Maintenance has raised the North

and South CWPH Roll-up doors approximately two feet to provide flooding relief. These

actions were directed to be performed in advance of the installation of the wave run-up

barriers, to ensure that while the barriers were installed, an additional flow path would be

created because the credited flow paths for the PMP external and turbine building

internal flooding events would be blocked during this time.

Final Safety Analysis Report Section 2.5 Hydrology regarding for the maximum

precipitation flood event states, in part, that the topography of the site results in

adequate natural drainage to remove this amount of water and limit ponding depth to

prevent adversely affecting safety related equipment. Contrary to these statements, the

newly created actions which were developed to compensate for the nonfunctional

natural drainage paths during wave barrier installation required use of additional features

not credited for external flooding events. Specifically, the actions included opening the

CWPH roll-up doors and routing flood waters through the CWPH and relying on internal

flood relief dampers to open and drain the water. The inspectors noted that the

10 CFR 50.59 screening documentation for Revision 6 of PC 80 Part 7, the revision

which added CWPH door actions to the procedure, did not include any discussion of the

actions to open the CWPH doors to provide a flood water flow path. The inspectors

observed that due to the licensees position that this action was in accordance with the

CLB, licensee personnel failed to screen or evaluate these actions under the

requirements of 10 CFR 50.59.

The inspectors noted that as a result of the failure to evaluate these actions under

10 CFR 50.59, the licensee failed to properly consider several factors associated with

the newly created drainage path that should have been evaluated. Some of these

factors included flood water flow rates through the open doors, the impact of debris and

slush from the outdoors being carried into the CWPH room and clogging the flood relief

dampers, the potential for substitution of unintended manual actions in place of passively

24

credited actions in the CLB, the impact of the cold temperatures on the equipment in the

rooms during the potentially extended periods of time during which the doors could be

open, and security impacts.

Analysis: The inspectors determined that the licensees failure to fully evaluate the

viability of newly created flooding drainage paths as required by 10 CFR 50.59(d)(1) was

a performance deficiency, because it was the result of the failure to meet the

requirements of 10 CFR 50.59; the cause was reasonably within the licensees ability to

foresee and correct; and it should have been prevented. The inspectors determined that

this finding has a cross-cutting aspect in the area of problem identification and

resolution, because the licensee failed to thoroughly evaluate issues to ensure that

resolutions address causes and extent of conditions commensurate with their safety

significance (P.2). Specifically, the licensee failed to fully evaluate a deficiency found in

PC 80 Part 7 associated with wave barriers blocking natural drainage paths, to ensure

that the corrective actions adequately addressed the problem.

The performance deficiency was screened in accordance with the guidance of

lMC 0612, Appendix B, and determined to be more than minor because the finding was

associated with the Mitigating Systems Cornerstone attributes of Protection Against

External Factors (Flood Hazard) and Design Control, and adversely affected the

cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (i.e. core damage).

Specifically, the licensee did not fully demonstrate that the availability, reliability, and

capability of mitigating systems would be maintained during flooding events due to the

sites failure to evaluate the viability of alternate flood drainage paths through the CWPH.

The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Tables 2

and 3, and Appendix A. Based on a review of Appendix A, Exhibit 2, Item 4.B, the

inspectors determined that this issue screened as having very low safety significance

(Green).

Because this issue involved the failure to perform a written evaluation pursuant to

10 CFR 50.59, Changes, Tests, and Experiments, it, by definition, impacted the

regulatory process. As a result, the traditional enforcement process was determined to

be applicable. In determining the severity level of the traditional enforcement aspect of

the issue, the inspectors identified that Subsection d.2 of Section 6.1, Reactor

Operations, of the NRC Enforcement Policy lists a 10 CFR 50.59 violation that results in

conditions evaluated by the SDP as having very low safety significance as an example

of a Severity Level IV violation. Because the associated finding was determined to be of

very low safety significance, this issue was determined to represent a Severity Level IV

violation under the traditional enforcement process.

Enforcement: Title 10 CFR 50.59(d)(1) requires, in part, that the licensee shall maintain

records of changes in the facility, of changes in procedures, and of tests and

experiments made pursuant to paragraph (c) of this section. These records must

include a written evaluation which provides the bases for the determination that the

change, test, or experiment does not require a license amendment pursuant to

paragraph (c)(2) of this section. Title 10 CFR 50.59(c)(2) lists several examples and

states, in part, that a licensee shall obtain a license amendment pursuant to

10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the

change, test, or experiment would meet the description of any of the listed examples.

25

Contrary to the above, on November 25, 2013, the licensee failed to perform an

evaluation against the criteria in 10 CFR 50.59(c)(2) for a change to procedure

PC 80 Part 7 to include actions to maintain functionality of drainage paths during

probable maximum precipitation and turbine building flooding events. Specifically,

PC 80 Part 7, Lake Water Level Determination was changed to include actions to open

the CWPH rollup doors to provide an additional drainage path while wave barriers were

in place, without evaluating the viability of reliance on additional flood features not

credited for external flooding in the CLB. Corrective actions for this issue included

actions to update the FSAR to describe the new flood paths, performing a 10 CFR 50.59

screening and 10 CFR 50.59 evaluation for the new drainage path which had put the site

outside of the CLB, revising a related functionality assessment, controlling external

flooding areas to ensure they are clear of debris, and creating a procedure to install

curtains on the CWPH rollup doors during periods when they were required to be open.

Because this violation was of very low safety significance and because the issue was

entered into the licensees corrective action program (CR 01946330), this violation is

being treated as a Severity Level IV NCV, consistent with Section 2.3.2 of the NRCs

Enforcement Policy. (NCV 05000266/2014007-03; 05000301/2014007-03; Failure to

Perform a Required 10 CFR 50.59 Evaluation)

The associated finding for this issue was evaluated separately from the traditional

enforcement violation; and therefore, the finding is being assigned a separate Tracking

Number. (FIN 05000266/2014007-04; 05000301/2014007-04; Failure to Perform a

Required 10 CFR 50.59 Evaluation)

(4) Failure to Establish EFR Attributes to Assess the Effectiveness of Corrective Actions

Introduction: The inspectors identified a finding of very low safety significance (Green)

and associated non-citied violation of 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, for the failure to ensure the effectiveness

review attributes for a significant condition adverse to quality would ensure the corrective

actions would eliminate or reduce the recurrence rate.

Description: The licensee performed a common cause analysis (CCA) of the two White

findings documented in NRC Inspection Reports 05000266/2012-009 and 2013-012.

The CCA was documented in CR 01896156. Each of the two white findings had a root

cause analysis (RCA) performed and the CCA determined whether common causes

from the RCAs existed. The licensee identified two CCAs. CCA 1 was Leadership has

not consistently driven the organization to identify risk significant conditions and evaluate

those conditions to ensure timely resolution. CCA 2 was Several examples of technical

procedure quality issues have led to workers applying knowledge based decision making

during activities resulting in additional risk to the station.

The CCA and the RCAs were performed in accordance with licensee procedure

PI-AA-100-1005 and as required by this procedure the licensee also established an EFR

plan. The purpose of the EFR was to outline the attributes needed to assess the

effectiveness of the corrective actions to prevent recurrence (CAPRs). The EFRs were

not limited to just CAPRs but could also apply to corrective actions when necessary.

26

The inspectors reviewed the EFRs established by the licensee for the two CCAs

identified in CR 01896156. The EFRs were to be performed six months following CAPR

implementation. The inspectors noted that of the five success criteria established by the

licensee three of them relied entirely upon NRC feedback. Common Cause Analysis 1,

criteria 1, required positive NRC Resident Inspector feedback regarding issue resolution

and timeliness. Common Cause Analysis 1, criteria 2, required zero findings with a

crosscutting aspect of H.1(a) [Decision Making - Systematic Process], and CCA 2,

criteria 1, required zero findings with a H.2(b) crosscutting aspect [training]. Discussions

with licensee personnel and a review of the CCA determined that use of H.2(b) was a

typographical error and that H.2(c) [Procedure Quality] was intended to be used.

The inspectors challenged the licensee regarding the use of NRC inspector findings as

one of the few measures of how effective their corrective actions had been implemented.

The inspectors were concerned with the use of performance measures that were not

under the licensees control, were informal, and had a zero tolerance.

The main focus of the inspectors concerns was that the licensee had originally failed to

identify the weakness and violations noted above and had not recognized the need to

correct them until the NRC observations. The inspector noted that this approach was

not proactive and that waiting to see if the NRC found any new items in the next six

months would neither demonstrate the problems had been corrected nor identify that

they had not been corrected. The inspectors concluded that the EFRs were not

effective.

Analysis: The inspectors determined that the licensees failure to establish EFR criteria

that would have identified whether the CAPRs had effectively resolved the conditions

was a performance deficiency warranting further review.

The inspectors determined that this finding was more than minor in accordance with

IMC 0612, Appendix B, because it was affected the Mitigating Systems Cornerstone

objective to ensure availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences.

The inspectors evaluated the finding using IMC 0609, Appendix A. The inspectors

determined the finding was of very low safety significance (Green) because the finding

was not a deficiency affecting the design or qualification of a mitigating structure, system

or component and did not result in a loss of operability or functionality. In addition, the

finding did not represent a loss of system or function, did not represent an actual loss of

function of a least a single train for longer than its technical specification allowed outage

time, and did not represent an actual loss of function of one or more nontechnical

specification trains of equipment designated as high safety-significance.

The finding had a cross cutting aspect in the area of problem identification and

resolution, specifically resolution, because licensee personnel failed to ensure the

corrective actions to prevent recurrence had effective attributes. (P.2)

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

and Drawings, requires, in part, that activities affecting quality be prescribed by

procedures of a type appropriate to the circumstances and shall be accomplished in

accordance with these procedures. Licensee procedure PI-AA-100-1005, Revision 8,

27

Root Cause Analysis, had been written and established in accordance with

10 CFR Part 50, Appendix B, Criterion V.

Step 4.11.2.B, of PI-AA-100-1005, required, in part, The effectiveness review plan

outlines attributes to verify, responsibility and due dates. The attributes of effectiveness

are the critical elements from those improvements that will guarantee success.

Contrary to the above, on February 7, 2014, the NRC inspectors identified that some of

the EFR attributes for CCA 1 and CCA 2, of CR 01896156 would not have assessed the

critical elements of the CAPRs and thus the verification that the corrective actions were

effective would not have been performed as required by PI-AA-100-1005.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the

Enforcement Policy, because it was of very low safety significance (Green) and was

entered into the CAP as CR 01938326. (NCV 05000266/2014007-05;

05000301/2014007-05, Failure to Establish EFR Attributes to Assess the

Effectiveness of Corrective Actions).

02.04 Independent Assessment of Extent of Condition and Extent of Cause

As directed by IP 95002, the inspectors independently assessed the validity of the

licensees conclusions regarding the extent of condition and extent of cause of the

issues. The objective of this requirement was to independently sample performance, as

necessary, within the key attributes of the cornerstones that were related to the subject

issues and to provide assurance that the licensees evaluations regarding the extent of

condition and extent of cause were sufficiently comprehensive. The extent of condition

review differs from the extent of cause review in that the extent of condition review

focuses on the actual condition and its existence in other places. The extent of cause

review should focus more on the actual root causes (RC) of the condition and on the

degree that these RCs have resulted in additional weaknesses.

.1 Extent of Condition

a. Inspection Scope

The inspectors conducted an independent extent of condition review of the (1) White

NOV for the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) issue; (2) the White

Flooding issue; and (3) and the Common Cause Evaluation of both issues. The

inspectors review focused on the conditions identified in the primary root causes

associated with the above issues.

The inspectors interviewed station personnel, and reviewed program and process

documentation, maintenance procedures, and corrective action documents. In addition,

the inspectors conducted field walk downs of safety related equipment that involved

possible alignment requirements such as pumps and motor-operated valves (MOVs).

The inspectors looked for installation conditions that may challenge alignment of rotating

equipment, as was the case with the TDAFWP. The inspectors also performed walk

downs of plant areas that could be impacted by the wave run-up design basis flooding

event. Walk down activities included evaluation of the locations where the wave run-up

barriers would be constructed, and assessment of the physical flood barriers and sand

bags that would be utilized to respond to a wave run-up event.

28

b. Assessment

The inspectors assessed the licensees extent of condition evaluation through their own

independent extent of condition review. However, this assessment was only possible

due to changes the licensee made to the initial extent of condition evaluation.

Additionally, significant actions still remained to be defined by the licensee to determine

with high confidence their corrective actions would be effective.

TDAFWP White Finding

The licensee defined the condition in RCE 10768931, TDAFWP Coupling Degradation

During IT 08 Run, as the 1 P-29 TDAFWP coupling degraded due to misalignment. The

setup condition was the misalignment exceeded the coupling vendor's specification. The

same-same condition would be any other identical couplings on the 1P-29 TDAFWP,

which there are none, and the coupling on the 2P-29 TDAFWP being misaligned. The

same-similar condition would be other pumps with the same model coupling and have

alignment problems. No other pumps at Point Beach used the Thomas 54 Size 262

flexible disc coupling. The similar-similar condition would be other pumps that use

Thomas flexible disc couplings and have alignment problems which identified seven

other sets of pumps, the only safety related pumps being the containment spray pumps.

The licensees CCA 1896156; Degraded Cornerstone - Mitigating Systems, Two

White Findings, conducted an in-depth review of the AFW degraded coupling root

cause analysis report and identified that the extent of condition performed under

RCE 01768931 only considered what other equipment used Thomas Flexible disc

couplings to ensure alignment criteria was specified in alignment procedures. The CCA

concluded a more appropriate extent of condition would have considered all rotating

equipment that has alignment criteria specified.

As a result, the CCA initiated actions 26 through 29 to have the system engineers for all

mitigating system pumps, review and revise assembly procedures to incorporate

TDAFWP pump lessons learned. However, CCA action 15 was to expand the extent of

condition assessment to include all rotating equipment that has alignment criteria

specified. This action was not yet defined or started and therefore its scope or

effectiveness could not be assessed.

The inspectors independent extent of condition review considered all safety related

rotating equipment where alignment may be needed to ensure expected operation and

reliability. Therefore, the inspectors selected a sample of pumps and MOVs. The

inspectors verified installation procedures for the pumps included in the action items

mentioned above were changed appropriately.

The inspectors performed a walk down of one set of Emergency Core Cooling Pumps

and a variety of plant configurations of MOVs with system engineers and maintenance

personnel. The inspectors did not identify any conditions that would challenge alignment

of these components during installation. The inspectors found that alignment of MOVs

was not required by vendor or licensee procedures as the MOVs should be inherently

aligned through the valve yoke. If alignment issues were to result from installation, they

were expected to be discovered through the as-left MOV testing. A small number of

MOVs had attached supports. Condition Report 01938749 was initiated to evaluate the

29

need to do MOV testing after installation of supports on MOVs to ensure installation of

the supports did not affect valve performance.

The inspectors reviewed a sample of the CAP and found the following condition reports

that contained concerns with equipment alignment. Condition Report 01216019

discussed cracking of a valve yoke in 1999 due to actions taken to alleviate a yoke

alignment issue. Condition Report 01660763 discussed a large amount of pipe strain

when installing pump 2P-73B in 2011 (similar to the issue with the TDAFWP). Condition

Report 01202954 discussed alignment issues with 2P-11B where the base has to be cut.

Condition Report 01879455 discussed alignment issues due to bearing housing fit-up.

Condition Report 01808901 discussed an alignment issue with the Emergency Diesel

Generator, G-01, circulation oil pump due to excessive pipe strain.

As discussed above, the licensees expanded extent of condition evaluation, CCA action

item 15, to include all rotating equipment that requires alignment had not been further

defined, but based on the inspectors review of previous CAP issues and walk downs, the

scope should include pumps, valves, fans, and diesels as a minimum. The evaluation

may conclude the condition does not exist in these components or that existing

processes adequately address alignment of the components.

The inspectors concluded the extent of condition was initially too narrowly defined, which

would not have been acceptable, but was subsequently expanded in the CCE. Based

on the walk downs, which did not identify challenges to alignment during installation, the

actions taken to revise the installation procedures for the mitigating system pumps and

expanded action to evaluate additional rotating equipment, the inspectors assessed this

aspect of IP 95002 was met for the TDAFWP White finding.

White Flooding Finding

The licensee described the condition for the White flooding finding as procedure

PC 80 Part 7, did not prescribe adequate barriers to implement external flooding wave

run-up protection features. The licensees extent of condition addressed other

external flood protection measures as well as additional external hazard protection

measures and commitments. The inspectors performed an independent extent of

condition by performing plant walk downs, interviewing personnel, reviewing corrective

action programs generated for site identified external flooding issues, and assessing

selected plant procedures.

During walk downs of the plant areas where flood barriers would be built, the inspectors

questioned plant personnel regarding possible bypass mechanisms around the flood

protection features. Specifically, the inspectors questioned whether storm drains outside

the CWPH that communicated directly with the lakeshore could present a wave barrier

bypass hazard. Licensee personnel stated they had only briefly considered these drains

but had rejected them as a possible bypass path without performing an analysis or any

follow-up. Following a request from the NRC inspectors for information regarding these

drain lines and the potential wave barrier bypass paths, the licensee performed an

engineering calculation to review the impacts. The calculation determined that the drain

paths did not in fact represent a significant threat to having high lake water bypass the

flood protection features. The inspectors determined that the calculation was neither

simple nor straightforward and should have been performed as part of the licensees

extent of condition.

30

During a review of the licensees corrective action program the inspectors observed that

licensee personnel had identified that the installation of the more robust flood protection

barriers would introduce an unintended consequence of blocking the natural flow path of

rain water and snow melt. The licensee had identified this unintended consequence

while performing Fukushima external threat calculations and not due to the extent of

condition review for the White flooding finding. This issue represented a flaw in the

licensees initial corrective action which was first put in place in March 2013 as an

immediate action to restore compliance. Inspectors noted that this issue should have

been identified prior to installation and represented another missed opportunity to

identify for their extent of condition. Instead, the inspectors noted that this left the site in

a position where they were still in discovery when the IP 95002 inspection team arrived

onsite.

Inspectors also noted a corrective action document generated several months after

completion of the RCE, and approximately one week prior to the inspection teams

arrival onsite, regarding conflicting AOP procedures. Specifically, the inspectors noted a

CR that stated the High Winds AOP was in conflict with the External Flooding AOP, in

that the former required CWPH roll up doors to be open and the latter required them to

be closed. The inspectors observed that invoking both procedures at the same time

could easily be required depending on weather conditions. The inspectors noted that

this was another example of late discovery, which represented an additional missed

opportunity for the licensee to have identified the issue during their RCE extent of

condition.

The inspectors review of external flooding procedures to ensure that the procedure was

adequately corrected to ensure protection of equipment during a design basis flood

yielded several deficiencies. These deficiencies are described in more detail in the

findings section of the report. Specifically, during the inspectors review of PC 80 Part 7

and PBF-2124 the inspectors identified a number of issues resulting in the determination

that both procedures were flawed and would not have accomplished their intended

function.

PC 80 Part 7 procedural deficiencies included error traps where steps can be performed

out of sequence (i.e. barriers installed before CWPH doors open); failure to include

CWPH doors in robust tag-out process to ensure their open position was controlled;

and direction to install barriers at +0.5 ft. plant elevation, which was not early enough in

accordance with the licensees timeline calculation. PBF-2124 procedural inadequacies

included a note that allowed them to rely on last months data for lake level if the current

months data was not readily available, direction to install barriers at the incorrect

threshold of +0.5 ft. plant elevation, and direction to install jersey barriers rather than the

more robust barriers associated with the licensees RCE corrective actions (reference to

the jersey barriers referred to the previous flooding strategy). The inspectors identified

that the same +0.5 ft. installation threshold error was made in the licensees external

flooding abnormal procedure, AOP 13C.

The licensees extent of condition did not extend to non-external event design basis

items because as stated in the RCE separate and rigorous processes already in

place to ensure site documentation is up to date and accuratefor instance, AOPs are

reviewed (and validated) on a regular basis to ensure quality and accuracy of the

procedure. Yet during the inspectors review it was observed that procedure technical

quality was determined by the licensee to be a root cause for the TDAFWP White

finding. The inspectors also noted that it would have been appropriate for the licensee

to more thoroughly evaluate the modification 10 CFR 50.59 process during their extent

31

of condition review, due to the integral role that the inadequate 10 CFR 50.59 review

played in the original performance deficiency. This may have also been appropriate in

light of the licensees failure to properly utilize the 10 CFR 50.59 process during

development of the modification to correct the performance deficiency, as discussed in

the findings section of this report.

The team concluded that the requirements of IP 95002 for the extent of condition were

not met for the flooding White finding.

c. Findings

No findings were identified.

.2 Extent of Cause

a. Inspection Scope

TDAFWP

The inspectors conducted an independent extent of cause reviewed based on the root

and contributing causes identified by the licensee in RCE 10768931, TDAFWP Coupling

Degradation During IT 08 Run. Licensee personnel identified the Root Cause as the

TDAFWP exhaust steam piping was not installed properly during original construction to

eliminate stresses on the turbine per vendor recommendations resulting in cold piping

spring and coupling misalignment. Contributing Cause 2 (CC2) was determined to be

that as-found alignment data was classified as information-only, resulting in no

evaluation of out-of-tolerance conditions and the procedures lacked acceptance criteria.

Contributing Cause 3 (CC3) was determined to be that the TDAFWP and turbine were

not aligned during original construction using vendor recommended dowels allowing

subsequent movement of equipment.

The inspectors determined that the root cause was narrowly focused and not a good

candidate to perform an independent extent of cause. In fact, most aspects of the root

cause were included in the extent of condition discussed above. Instead the inspectors

selected CC2 and CC3 to perform the independent extent of cause.

The inspectors reviewed the licensees extent of cause evaluations to assess whether

they were of sufficient breadth and depth to accurately capture the extent of the causes.

The inspectors independent extent of cause evaluation involved in-plant walk downs

and observation of work activities, interviews with station management and staff, reviews

of program implementing procedures, reviews of program monitoring and station

improvement efforts, and comprehensive searches of the corrective action program.

White Flooding Finding

The inspectors performed an independent extent of cause based on the root and

contributing causes in the licensees RCE. The inspectors focused their review on the

licensees two identified root causes, as well as the two contributing causes identified in

the RCE. The root causes identified by the licensee included inadequate identification

and understanding of the external flooding CLB (RC1), and inappropriate prioritization of

flood protection deficiencies in the corrective action program based on

conditional/immediate station risk perceptions (RC2). The contributing causes the

licensee identified included a lack of clear supporting detail in station documents for

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external events combined with a lack of use and understanding of license basis (CC1),

and a lack of formality and rigor regarding the stations follow-up and resolution of NRC

concerns (CC2).

The inspectors reviewed the licensees extent of cause evaluations to assess whether

they were of sufficient breadth and depth to accurately capture the extent of the causes.

The inspectors interviewed licensee management and personnel, reviewed program and

process documentation, performed plant walk downs, reviewed licensee program

monitoring and improvement efforts, and reviewed corrective action documents.

b. Assessment

TDAFWP

The inspectors determined that the extent of cause evaluations conducted by the

licensee for the TDAFW issues were narrowly focused. The extent of each cause

evaluations conducted by the inspectors broadly considered other programs and

components that may be affected by similar causes. The limited sampled performed by

the inspectors did not identify significant issues to concluded the cause would be

applicable in those areas. Therefore, based on the actions taken so far, and with the

additional actions entered into the licensees corrective action program, overall, the

inspectors concluded that Extent of Cause objectives of the 95002 inspection procedure

were met for the TDAFWP finding. The inspectors noted a number of licensee actions

are yet to be defined or completed as discussed below. Specific results of the

inspectors review of the causes and program areas are discussed below.

CC2: RMP 9044-1 Identified As-Found Alignment Data as Information Only Resulting In

No Evaluation of Out-of-Tolerance Conditions and Lacked Acceptance Criteria

The inspectors determined that the vibration monitoring and In-service Test (IST)

procedures require reviews by appropriate departments, including operations and

engineering. The procedures do not discuss information only data. Personnel involved

with these programs stated all data taken was reviewed by engineering. The review of

the corrective action program only identified the following issues.

Condition Report 019118667 described a condition found during review of the 1P-11A

coupling setting. It was identified that the as found coupling gap was recorded as 0.046

inch. The procedural requirement in RMP 9006-2A, required the gap to be 0.125 inches

per the OEM installation requirements for the Falk Model 1080T20 coupling. A review of

the last performed pump work on 1P-11A in 2010 under WO 392829, which included

procedure RMP 9006-2A, recorded the coupling back of hub to back of hub dimension

as 7.035 inches and did not record the actual gap, as the coupling was not removed.

The as found coupling back of hub to back of hub dimension under the current work was

7.034 inches with a gap of 0.046. Based on this information and that the coupling hubs

have not been replaced, the as found coupling appears to have been set incorrectly

since the coupling was last removed in 2007 under WO 188114.

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Another CR 01895229 stated that during the previous TDAFW Pump 95001, the NRC

identified that routine maintenance procedures lack acceptance criteria.

During this review, some instances were found where as-found alignment data is now

being evaluated. The inspectors did not identify instances where vibration or IST data

was not evaluated.

The licensees extent of cause evaluation for CC2 considered as-found Thomas Series

54 Size 262 coupling alignment data that was being treated as information-only. It found

this cause only applied to procedure RMP 9044-1 because the P-29 turbine-pump

combination is the only equipment that utilizes the Thomas Series 54 Size 262 coupling.

The licensee determined RMP 9044-1 needed to be revised to include acceptance

criteria for the critical parameters of the Thomas Series 54 Size 262 coupling that could

affect operability, and included formal evaluation by engineering if any of these criteria

are exceeded. No other corrective actions were required.

The licensee evaluation also included other Thomas flexible disc pack coupling

alignment data and determined as-found data that is not evaluated applied to

procedures or work orders associated with the following equipment:

• P-028 Main Feedwater Pumps (Series 51 Size 450)

• P-007 Monitor Tank Pumps (Series DBZ-A Size 101)

• P-014 Containment Spray Pumps (Series DBZ-A Size 101)

• P-099 SGFP Seal Water Injection Pumps (Series DBZ-C Size 126)

• P-004 Boric Acid Transfer Pumps (Series DBZ-C Size 126)

• W-001 Containment Accident Recirculation Fans (375SN)

• W-004 Containment Reactor Cavity Cooling Fans (Series AMR)

The licensee action was to review the procedures or work orders for the above

equipment and revise them as necessary to include acceptance criteria for the critical

parameters.

The inspectors found the licensee extent of condition to be narrowly focused on either

the specific Thomas Series 54 Size 262 coupling or other Thomas flexible disc pack

couplings and did not consider other alignment procedures or procedures and programs

where as-found or information-only date may be taken and not evaluated. However, the

inspectors only found a few instances in the CAP where this weakness existed and

therefore could not conclude the cause identified extended into other equipment and

programs and therefore concluded this aspect requirements of IP 95002 was adequately

met for CC2.

CC3: 1 P-29 Pump and Turbine Were Not Aligned During Original Installation Using

Vendor Recommended Dowels Allowing Subsequent Movement of Equipment

Through review of a sample of vendor manuals, the inspectors did not identify any

vendor guidance concerning alignment that should have been incorporated into licensee

procedures. However, there were some issues identified in the corrective action

program that the inspectors considered representative of CC3.

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For instance, CR 01920659, dated November 14, 2013, found that the 1P-029 as-found

alignment checks were outside the acceptance criteria of RMP 9044-1, Auxiliary

Feedwater Pump Terry Turbine Overhaul. The acceptance criteria for horizontal

alignment (offset) is -0.002 to 0.002 and, the as-found results were -0.0037 for horizontal

alignment. The as-found vertical alignment was satisfactory. The 1P-029-T was

realigned per RMP 9044-1 as part of the contingency work plan. Although the 2P-029

was doweled in accordance with vendor manual instructions, there was no mention of

doweling in this procedure.

Condition Report 01217509 dated June 8, 2000, states the post maintenance test

(PMT) for WO 9925677 indicated a probable alignment problem with P-132. Work

Order 9927144 was created to perform a "hot" alignment on P-132. The term "hot"

alignment is more commonly referred to in vendor manuals as a "final" alignment. The

vendor manual for all Goulds 3196 pumps calls for an initial alignment to be performed

when a pump is installed or reinstalled. The manual then calls for a final alignment to be

performed "after the unit has been run under actual operating conditions for a sufficient

length of time to bring the unit up to operating temperature." The manual goes on to say

that the final alignment should be checked after approximately one week of operation.

The manual also states that "the final alignment procedure......must be followed". Based

on the inspectors review, final alignments described in the Goulds pumps' manual are

not performed at Point Beach Nuclear Plant. These final alignments should be

performed as they are specifically called for by the pump manufacturer. Pump

misalignment could cause premature failure of critical pump parts such as bearings and

seals.

Another CR 01195885, dated April 17, 2001, stated that oil analysis shows evidence of

bearing wear for a safety injection pump motor. During alignment, the motor shaft was

apparently not at the mechanical center as recommended by the manufacturer. It was

mis-positioned such that contact was made at the inboard bearing thrust face with the

coupling compressed.

The inspectors also identified current observations by oversight organizations that are

indicative of conflicts with vendor manual instructions. Point Beach Daily Quality

Summary, dated October 16, 2012, discussed an observed activity for AF-00109,

P-38A Auxiliary Feed Pump Discharge Check Valve Inspection. It noted that the work

instructions were minimal and lacked warnings to avoid cocking the bonnet during

disassembly and reassembly that were stated in the vendor technical manual (VTM).

The scope in the WO instructions was written from the lift check valves vendor technical

manual and is different from what is listed in the Engineering technical basis. This

observation also indicates possible alignment issues with this check valve that supports

the need to consider valves during evaluation of the extent of cause for CC2.

Another observation, Point Beach Daily Quality Summary for 2P-29 TDAFW Pump

Assembly, dated November 19, 2012, noted that CR 01824455, Functional Criteria Not

Met, was initiated by Maintenance for the failure of the inboard bearing clearance to

meet the functional criteria. The System Engineer provided additional information to

CR 01824455 on November 17, 2012 stating that the functional criteria from preceding

Step 5.23.17 should have replaced the current criteria. The system engineer initiated

PCR 01825115 to put the correct criteria into the procedure. In light of the alignment

35

issues with this pump, the inspectors were concerned the licensee process did not

account for the latest vendor guidance to be entered into the applicable procedures.

After completion of the independent extent of cause for CC3, the inspectors reviewed

the licensees extent of cause for CC3. The licensee justified not doing an extent of

cause on CC3 base on it being unique to the TDAFWPs. Justification was based on the

following:

Since the piping misalignment issue has been resolved on 2P-29 and it is

not experiencing the governor valve chugging problem, no extent of cause

is required for this maintenance activity. The Terry turbine and pump are

unique in design compared to other driven pumps or components. Most

pumps and other pieces of equipment are driven with an electric motor. In

the normal configuration, the pump is considered the fixed point due to

being hard piped with suction and discharge pipe and is doweled once set.

The motor is moved as needed to obtain the required alignment tolerances

and is not doweled. Moving the motor to obtain proper alignment is being

restrained by hold down bolts. Slight movement of the motor to

accomplish proper alignment is permitted since only the connection to the

motor is the flexible power source conduit. For the AFW turbine and the

pump, both are hard piped, which is a significant challenge during

alignment. In addition, both the turbine and pump are to be doweled per

their respective vendor manuals, which is unique compared to other

rotating pieces of equipment. This condition of no dowels has existed

since startup and is considered an original which included procedure RMP

9006-2A construction deficiency of which the cause will not be determined.

Therefore no extent of cause is justified for this.

With a relatively small sample the inspectors found issues that had been identified

previously by the licensee that indicated CC3 may extend to other equipment with

vendor manual information. Therefore, the inspectors concluded the licensees extent of

cause evaluation for CC3 was narrowly focused and may not capture other vendor

guidance into licensee procedures. Condition Report 1939217 was initiated for this

observation. The recommended corrective action was to review a sample of vendor

recommendations contained in VTMs for safety related equipment to determine whether

there are broader issues associated with implementation of vendor recommendations.

While the inspectors determined the licensees extent of cause evaluation was narrowly

focused, other than the doweling guidance, no instances were identified where vendor

guidance was not appropriately incorporated into licensee procedures. Based on this

and the licensee action referenced above, the inspectors concluded the 95002

procedure requirements were satisfied.

White Flooding Finding

The inspectors determined that the extent of cause evaluations conducted by the

licensee for the External Flooding deficiencies were narrowly focused. Each of the

inspectors independent extent of cause evaluations broadly considered other programs,

procedures, functional areas that may be affected by similar causes. The limited sample

performed by the inspectors identified a few notable issues which are documented in

36

detail in the findings section of this report and the section below. Based on the actions

taken so far, the inspectors concluded that Extent of Cause objectives of the 95002

inspection procedure were not met for the Flooding finding. Areas of concern will be

reviewed as part of a future inspection. Specific results of the inspectors review of the

causes are discussed below.

RC1: Inadequate Identification and Understanding of the External Flooding CLB

The inspectors reviewed the licensees extent of cause evaluation for the first root cause

identified, RC1. Specifically, RC1 was identified as less than adequate identification

and understanding of the external flood protection design and licensing basis resulted in

loss of high lake level protection measures in 1996 when AOP 13B was cancelled.

Inspectors reviewed corrective action programs from the preceding 2-year period,

external events program controls, and general procedures in the areas of High winds,

Tornados, High Energy Line Breaks, Internal Flooding, and External Flooding, and

walked down related plant areas to independently assess whether the licensee had

appropriately identified deficiencies in understanding and identification of the design and

license basis.

No significant issues were identified. However, inspectors noted examples described in

the findings section of the report, where the licensee had failed to fully recognize impacts

of the wave run up barriers during the probable maximum precipitation (PMP) and

turbine building flooding event until the 95002 inspection team arrived onsite. The

inspectors noted that given the topography of the site and associated drainage

characteristics, this issue should have been more readily identified as part of the extent

of condition and extent of cause evaluations.

In addition, as noted in the findings section of this report, the licensee failed to recognize

that the conflict with the barriers resulted in a failure to comply with the CLB and the

need to open the CWPH roll-up doors constituted a compensatory action that needed to

be reviewed in accordance with 10 CFR 50.59. The inspectors noted that this issue was

served as an example where licensee personnel still demonstrated a lack of

understanding of the CLB, which served as evidence that the extent of cause for this

root cause have not been fully probed and deficiencies corrected.

RC2: Inappropriate Prioritization of Flood Protection Deficiencies in the Corrective

Action Program Based on Conditional/Immediate Station Risk Perceptions

The inspectors reviewed the licensees extent of cause evaluation for the second root

cause identified, RC2. Specifically, RC2 was identified as the degraded function of high

lake level protection measures for wave run-up identified in the corrective action

program were inappropriately prioritized based on conditional/immediate station risk

perceptions rather than compliance with license commitments resulting in untimely

resolution of the issues.

During review of RC2, inspectors interviewed plant personnel to evaluate general

understanding of the flooding deficiencies, recognition of associated risks, and

effectiveness of site communication campaigns. As previously noted, inspectors

observed that broader issues with risk recognition may still exist, based on discussion

with site personnel.

37

The inspectors assessed the extent of cause relative to the licensees failure to

characterize the wave barrier as nonfunctional and thus failed to properly prioritize

fixing the deficient strategy due to the lack of risk recognition. The inspectors noted that

of the 11 functionality assessments (FA) that the licensee sampled as part of their extent

of cause, and including an additional FA, excluded from the licensees sample because

the NRC had already found it deficient, half were found to be deficient in their

conclusions or logic. The inspectors observed that no action was taken to correct these

deficiencies, as the CR written on the results of the review was closed to no action. In

addition, no action was taken to learn from the results of the review, or probe these

results more deeply due to reliance on some procedural changes being made to the FA

process.

The inspectors noted that the sites focus on the perception that these deficient FA

conclusions were non-consequential had parallels to the White flooding finding root

cause. Specifically, the licensee had drawn the wrong FA conclusion, but plant

personnel had determined that it did not matter as long as the correct action was

ultimately taken. The inspectors observed that in the case of the original White Flooding

finding, site personnel had not properly addressed the deficiency even though there was

a belief that the correct action had been taken. The inspectors noted that the licensee

would have been driven to correct the deficiency more promptly if the FA conclusion had

been correctly classified as non-functional. This highlights the importance of drawing the

correct functionality conclusion. The inspectors concluded that to ensure correction of

the deficiencies associated with these FAs, and as an extension, the root cause that

drove them to perform the functionality assessment sample, it may have been

appropriate to enact more robust corrective actions to arrest the trend.

The inspectors learned during the functionality assessment review, as documented in

CR 01924763, FA errors & less than adequate corrective action program threshold, an

individual had discovered deficiencies in the conclusions of several FAs, and chose not

to write a CR because they felt that initiation of a new CR would constitute low value

work. The inspectors noted that this example served as a data point of an individual that

may still be focused on what they believe is or is not significant, without looking at the

bigger picture, and failing to write a CR to ensure that risks could be evaluated.

Inadequate corrective action program threshold and risk recognition were common to the

flooding root cause and common cause evaluations. The inspectors questioned whether

this might be an indication that the workforce has not been fully reached by licensee

communications focused on fixing licensee personnels lack of risk recognition, and

instilling them with the objective to prove that something is safe.

The inspectors noted that in response to the CR 01924763, less than adequate

corrective action program threshold this CR was closed to no action, with a note that

stated that coaching was provided. Inspectors noted that without any review of the

behavior documented in the CR, it would be difficult for the licensee to determine

whether this behavior was a single isolated incident, or more of a wide spread problem.

Inspectors noted that it may have been appropriate for the licensee to take action to

make this determination so that more robust corrective actions than coaching could be

taken, if necessary.

38

The inspectors also noted that because the extent of cause was not extended from the

FA process to a similar process, the Operability Determination process, the licensee

missed an opportunity to implement robust corrective actions to address deficiencies in

the operability determination process. The inspectors noted that within the previous

2 years, there had been approximately five NRC findings associated with inadequate

operability determinations. The licensee noted that they had adopted a new operability

determination process procedure in August of 2013, and had taken actions as a result of

an April 2013 Condition Evaluation to perform one-time trainings for Operations and

Engineering to improve operability determination process knowledge. The inspectors

noted that Condition Evaluations serve as lower level evaluations that do not generally

probe deeply into issues, and may not reveal all aspects of a complex issue. Inspectors

also noted that actions to perform one-time trainings may not be robust enough to

ensure sustainable improvement. The inspectors concluded that given the critically

important function that operability evaluations serve, it may have been appropriate to

enact more robust corrective actions to ensure improvement in this area.

CC1: Lack of Clear Supporting Detail in Station Documents for External Events

Combined with a Lack of Use and Understanding of License Basis

The inspectors reviewed the licensees extent of cause evaluation for the first

contributing cause identified, CC1. Specifically, CC1 was identified as deficiency in

having clear supporting detail in station documents for external events combined with a

lack of use and understanding of license basis resulted in the FSAR requirements

remaining unmet.

Inspectors reviewed corrective action programs from the preceding 2-year period,

external events program controls, and general procedures in the areas of High winds,

Tornados, High Energy Line Breaks, Internal Flooding, and External Flooding, and

walked down related plant areas to independently assess whether the licensee had

appropriately identified deficiencies in clear supporting detail in station documents

associated with the license basis.

No significant issues were identified. However, inspectors identified several deficiencies

with the licensees failure to ensure clear supporting detail existed in station documents

associated with internal flooding. Specifically, inspectors noted that although during a

design basis turbine building flooding event, the site was crediting tripping the circulating

water pumps to mitigate the flood with a short specified amount of time, i.e. 34 minutes

or less, the site failed to evaluate and control this action under the time critical operator

action procedure. In addition, inspectors noted that the site had chosen to credit failure

of the turbine building roll up door during the same internal flooding event. Inspectors

identified that the site had failed to upgrade this door to an augmented quality

classification, despite the fact that they had taken action to credit the door in the design

basis to perform the safety related function of flood relief.

The inspectors also noted that reliance on the failure of the turbine building door for the

internal turbine building flooding event was not clearly articulated in changes the

licensee made to the FSAR, in that the TDAFW pump rooms noted that the door was

credited for flood relief, but the EDGs did not contain the same statement despite a

similar reliance on the same door. These issues were entered into the licensees

corrective action program. The inspectors determined that these issues could be related

39

to CC1, in that station documents did not clearly define and control features that were

credited to mitigate internal flooding scenarios.

CC2: Lack of Formality and Rigor Regarding the Stations Follow-Up and Resolution of

NRC Concerns

The inspectors reviewed the licensees extent of cause evaluation for the second

contributing cause identified, CC2. Specifically, CC2 was identified as stations rigor for

follow up on NRC concerns lacks formality and as a result the CR written for the

1Q2012 URI was not validated for accuracy, nor contained the necessary action, thus

contributing to the untimely resolution of potentially degraded flood protection

measures.

During review of CC2, inspectors identified that the licensees extent of cause was

narrow, and should have focused more broadly. Specifically, the licensees evaluations

focused only on improvements and deficiencies associated with the tracking and

resolution of NRC concerns. The inspectors questioned whether the site should have

looked across the organizations at similar processes and interactions with other external

stakeholders. Specifically, the inspectors noted that tracking and resolution of nuclear

oversight, corporate nuclear review boards, management review board, and

independent site evaluations may have similarities to the NRC issue tracking and

resolution processes. The inspectors noted that the site missed an opportunity to

identify improvements in these processes. The inspectors did not identify any instances

where the site had not appropriately tracked or resolved issues associated with these

groups, but inspectors also recognized that deficiencies in these areas may not be

readily identifiable due to the nature of these interactions.

The inspectors concluded the 95002 procedure requirements for the flooding White

finding were not satisfied.

c. Findings

No findings were identified

02.05 Safety Culture Consideration

a. Inspection Scope

As part of the current 95002 inspection, the inspectors independently confirmed that a

number of safety culture components that contributed to the risk significant issues that

were the subject of this inspection were identified in the licensees RCEs. The licensees

root cause evaluations included a discussion of the applicable safety culture

components described in Regulatory Issue Summary 2006-013, Information on the

Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture,

(ADAMS Accession No. ML061880341) as they applied to the violations and findings.

The licensee determined that weaknesses in decision making (conservative

assumptions and systematic process), resources (procedures/work instructions), work

practices (oversight), work control (planning), and the corrective action process

(low threshold and evaluations) were the most prevalent safety culture attributes. The

licensee also included the results of a 2013 station nuclear safety culture self-

assessment and employees concern program site pulsing surveys. For each of the

40

identified prevalent and contributing safety culture components, the inspectors confirmed

that the licensee established corrective actions to address the issues.

Assessment

The inspection team independently confirmed a sample of other safety culture

components which contributed to the issue(s) that were also identified in the root cause

analysis. These additional safety culture components included weaknesses in the CAP

and resources. For each of the identified prevalent and contributing safety culture

components, the inspection team confirmed that the licensee established appropriate

corrective actions to address the issues. Some corrective actions are complete, but

pending corrective actions and effectiveness of those actions has not been confirmed to

a point where the NRC has confidence that the licensees actions are sufficient to

address and correct the causes and issues. During the course of interviews with

licensee personnel, the inspection team asked interviewees questions related to safety

conscience work environment (SCWE) to determine if the licensees staff were reluctant

to raise safety concerns or if fear of retaliation existed for raising safety concerns. The

inspection team did not identify concerns related to SCWE.

The inspection team confirmed that the licensees root cause, extent of condition, and

extent of cause evaluations appropriately considered the safety culture components as

described in IMC 0305, Operating Reactor Assessment Program.

The inspectors observed that the previously cited example of a failure to initiate a CR, as

described in CR 01924763, FA errors & less than adequate CAP threshold, was an

important data point from a safety culture and CR initiation standpoint. This CR

documented an individuals failure to write a CR to document deficiencies in the

conclusions of several functionality assessments. The inspectors noted that while the

issue itself was just one data point, the licensees failure to act to determine the extent to

which those behaviors were prevalent onsite was an additional data point in the area of

safety culture. The inspectors noted that the licensee had instead closed the CR to no

action, and noted that coaching had been provided. The inspectors determined that

investigative actions may have been appropriate to assist in the licensees assessment

of whether their RCE corrective actions to improve CR initiation and risk recognition had

adequately reached the working level staff. This may have especially been appropriate

given the fact that similar inappropriate CAP threshold issues played a role in the

common cause for the greater than green findings being evaluated during the 95002

inspection.

Inspectors noted that the O.2a safety culture component may not have been adequately

considered during the licensees safety culture evaluation. Specifically, O.2a is focused

on ensuring that appropriate training and knowledge transfer was in place to ensure

technical competency of staff. The inspectors noted that the licensee marked this

aspect as not applicable. The inspectors observed that this safety culture aspect may

have played a role in the licensees root cause associated with licensee staffs failure to

understand the CLB. Mainly, the inspectors noted that training and knowledge transfer

could have increased licensee personnels understanding of the CLB. The inspectors

observed that at the least, this training and knowledge transfer could have prompted the

identification of vague requirements in the design basis or licensee staffs lack of full

understanding of the CLB. The inspectors noted that this could have driven resolution of

questions on requirements.

41

The inspectors noted that subject matter experts at the site who were charged with

ownership and knowledge of the external flooding program and other functional areas,

did not have any qualification cards or required subject matter trainings to ensure their

competency. This remained unchanged after the finding. The inspectors noted that

corrective actions to provide general external events training and to develop a formal

external events program may have appropriately addressed concerns about subject

matter experts training adequacy, as the procedure consolidated requirements into

controlling program procedures. However, the inspectors concluded that more

specialized training could have increased defense in depth in the training and knowledge

transfer areas.

The inspectors concluded the 95002 procedure requirements were satisfied for the

TDAFWP finding but not for the White flooding finding.

b. Findings

No findings were identified

02.06 Evaluation of IMC 0305 Criteria for Treatment of Old Design Issues

The licensee did not request credit for self-identification of an old design issue.

Consequently, the subject risk significant issues were not evaluated against the

IMC 0305 criteria for treatment of an old design issue.

4OA5 Other Activities

The inspectors utilized other inspection procedures as part of the assessment of the

licensees performance. The following inspection samples were completed as part of

this inspection.

• 71111.01 - External Flooding - 1 sample

• 71111.06 - Internal Flooding - 1 sample

• 71111.15 - Operability Evaluations - 1 sample

• 71152 - Problem Identification and Reporting - Annual Follow-Up

of Selected Samples - 1 sample

4OA6 Management Meeting

Exit Meeting Summary

On March 6, 2014, the inspectors presented the inspection results to

Mr. E. McCartney, Site Vice President, 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.

ATTACHMENT: SUPPLEMENTAL INFORMATION

42

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

E. McCartney, Site Vice President

R. Wright, Plant General Manager

R. Weber, Operations Director

M. Millen, Licensing Manager

K. Longston, Acting EP Manager

J. Atkins, Systems Engineering Manager

B. Beltz, Assistant Operations Manager

F. Hennessy, Performance Improvement Manager

J. Pruitt, Site Quality Manager

R. Welty, Radiation Protection Manager

R. Harrsch, Engineering Director

D. Lauterbur, Training Manger

P. Wild, Design Engineering Manager

L. Christensen, Licensing Project Manager

B. Scherwinski, Engineering Analyst II

T. Schneider, Licensing

F. Huber, Projects Manager

S. Cassidy, Communications Manager

C. Trezise, Director Special Projects

M. Ley, Civil/Mechanical Engineering Supervisor

T. Lesniak, Mechanical Maintenance Department Head

M. Maertens, Business Operations Manager

R. Clark, Licensing

S. Ruesch, Employee Concerns Program Manager

J. Petro, Licensing Director

A. Gustafson, Training

K. Locke, Licensing

Nuclear Regulatory Commission

A. Boland, Director, Division of Reactor Projects

J. Cameron, Chief, Branch 4, Division of Reactor Projects

K. Barclay, Acting Senior Resident Inspector Point Beach

R. Elliott, Acting Resident Inspector Point Beach

1 Attachment

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000266/2014007-01 NCV Failure to Take Corrective Actions to Address External

05000301/2014007-01 Flooding Procedure Deficiencies05000266/2014007-02 NCV Failure to Maintain External Flooding Procedure to

05000301/2014007-02 Address All Possible CLB Floods05000266/2014007-03 NOV Failure to Perform a Required 10 CFR Part 50.59

05000301/2014007-03 Evaluation

05000266/2014007-04 FIN Failure to Perform a Required 10 CFR Part 50.59

05000301/2014007-04 Evaluation

05000266/2014007-05 NCV Failure to Establish EFR Attributes to Assess the

05000301/2014007-05 Effectiveness of Corrective Actions

Closed

05000266/2014007-01 NCV Failure to Take Corrective Actions to Address External

05000301/2014007-01 Flooding Procedure Deficiencies05000266/2014007-02 NCV Failure to Maintain External Flooding Procedure to

05000301/2014007-02 Address All Possible CLB Floods05000266/2014007-03 NOV Failure to Perform a Required 10 CFR Part 50.59

05000301/2014007-03 Evaluation

05000266/2014007-04 FIN Failure to Perform a Required 10 CFR Part 50.59

05000301/2014007-04 Evaluation

05000266/2014007-05 NCV Failure to Establish EFR Attributes to Assess the

05000301/2014007-05 Effectiveness of Corrective Actions

2

LIST OF DOCUMENTS REVIEWED

The following is a partial 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 or 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.

Corrective Action Documents

CR 01195739, CCW Pump Vibration

CR 01195885, Oil Analysis Shows Evidence of Bearing Wear on Safety Injection Pump Motor

CR 01196175, G-02 Exhibited High Axial Impact-Type Acceleration

CR 01200210, RMP For Reactor Coolant Pump Uncoupling Questioned

CR 01200598, Refueling Water Storage Tank Throttle Valve Difficult To Operate

CR 01202954, 2P-11B Alignment Problems

CR 01208186, G-01 EDG Bearing Vibration

CR 01208318, RCS Piping Stress

CR 01212030, Service Water Pump Gland Follower Improperly Aligned

CR 01215799, Inadequacies Identified In SI Pump Routine Maintenance Procedure

CR 01216019, Potential for Cracking In MSB Lift Yoke

CR 01217509, P-132 BDE Distillate Pump Alignment

CR 01390003, License Renewal Exam of STP-00014 has Minor Indication

CR 01610365, P-032C SW Pump Shaft Vibration Trending High

CR 01633548, NOS Identified IER1 11-1, Flood Barrier Door Inspection

CR 01639502, Jacking Bolt Broken For Motor Alignment

CR 01655812, 2P-10B Bearing Housing Bracket Jack Bolt Holding Alignment

CR 01660763, P-73A/B Suction And Discharge Pump Piping Misalignment

CR 01678709, NRC Issues Position on Missile Protection For G-01/02 Exhaust

CR 01691196, Operability Determination Issues Across Fleet

CR 01723755, Safe Shutdown Fire Dampers No Inspected

CR 01726015, FSAR Questions Regarding Cross Over Steam Dump Testing

CR 01727221, Plant Safe Shutdown Equipment Exposed To Tornados

CR 01736062, High Energy Line Break Door Issues

CR 01748940, Tornado Hazard

CR 01757131, Potential Violation RSPS Degraded Function

CR 01760171, G-01 and G-02 EDGs Declared Inoperable

CR 01762122, Design Basis Docs On Tornado Missiles

CR 01768931, 1P-29 Turbine Driven Auxiliary Feedwater Pump Degraded Coupling

CR 01771762, Green Finding - Weld Design Deficiency in the EDG Missile Protection Barriers

CR 01779635, Green Finding - Failure to Incorporate WOG ERG, Revision 2 into the EOPs

CR 01780474, G05 Control System Does Not Control Well

CR 01799222, 1P-28B, MFW Pump, High Vibration As-Found Alignment Data

CR 01801696, Quarterly DQS of a Licensing Topic

CR 01804588, Inadequate Scoping of Non-Safety Related System into Maintenance Rule

CR 01805402, Procedure PC 80 Part 7 Lake Water Level Determination Issues

CR 01806402, Procedure PC 80 Part 7 Lake Water Determination Issues

CR 01806545, Inconsistent Application of IPEEE Information in CLB

CR 01807841, Sand Bags Erroneously Eliminated From PB Flood Contingencies

CR 01807866, WR - Obtain Hot and Cold Pump And Motor Growth Readings

CR 01808661, Failure to Implement Risk Management Actions During Emergent Work Activities

3

CR 01808901, Coupling Misalignment On 0P-217A G-01 Circulation Oil Pump

CR 01809095, Deficiencies In PC 80 Part 7, Lake Level Determination

CR 01816327, Missing Appendix R Calculations

CR 01824582, PC 80 Part 7 CA 01809095 Due July 31, 2013

CR 01826212, Generator to Engine Coupling Is Degraded

CR 01826753, Coupling on Turbine Has Minor Damage

CR 01833683, Green Finding - Failure to Update the Fire Emergency Plan

CR 01845168, CMP for EN-AA-203-1001 Revision 10 (OD/FA) Implementation

CR 01847140, G-05 Functionality During Severe Weather

CR 01849522, G01/G02 Missile Shield Impact on External Flooding

CR 01850776, 2P-028A High Vibration At Drive End Bearing

CR 01851639, Green Finding - Failure to Submit LER Within 60 Days

CR 01853775, Basis for Flood Barriers Not Referenced In FSAR

CR 01853779, Current Licensing Basis for External Flooding Not Changed

CR 01855615, Resident NRC Inspector Roof Inspection Questions

CR 01856318, FSAR Not Updated for External Flooding Features

CR 01856322, Failure to Establish Adequate Procedures to Respond to PMP Event

CR 01856327, Failure to Maintain Features to Address Max Wave Run Up

CR 01860140, Prior to Starting Work Problems Found With TDAFWP Work Package

CR 01861967, Recent Issues Related to Operability/Functionality, April 1, 2013

CR 01863557, FSAR Errors Identified in Self-Assessment

CR 01863560, High Energy Line Break Door Issue Trending

CR 01875052, Electrical Short Circuit Protection Issues

CR 01875056, Electrical Short Circuit Protection Issues

CR 01877254, G-05 Excessive Hunting at Peak Load

CR 01879455, 2P-011B Pump OB Bearing Doweling Issue

CR 01878130, 2013 CAP FSA - CR Initiation Sensitivity

CR 01880011, Calculation 2005-0053, Revision 1 Presents Appendix R Issues

CR 01883633, Flooding Root Cause Evaluation; Revision 3

CR 01886923, Determine If An Issue Was a Missed Opportunity - Flooding

CR 01889400, Condition Evaluation Did Not Evaluate Scope Identified in Parent CR 01763937

CR 01889518, Final Effectiveness Review Prompt Operability Determinations and

Functionality Assessments

CR 01892543, Interim Actions Were Not Fully Effective (EFR 1889518)

CR 01894831, 95001 Inspection AR Screened as CAQ

CR 01894925, NRC 95001 RCE 01768931 Enhancement

CR 01895229, Routine Maintenance Procedures Lack a Specific Standard for Alignment Data

CR 01896156, Degraded Cornerstone - Mitigating Systems Two White Findings

CR 01900061, Functionality Assessment CA1806402-01 Conclusion Questioned

CR 01901996, ACE for Green Finding for Probable Maximum Precipitation Event Controls

CR 01902111, Validate That AOP-13C Will Meet Station Blackout Requirements

CR 01907036, 95002 VSGR Door Gaps Documentation Potential Deficiency

CR 01907864, 95002 Preps: Difference in Annual Snowfall Levels in FSAR

CR 01912749, Subsoil Drainage System is Blocked

CR 01914914, 2-P11A Pump Alignment Challenges

CR 01917384, Unable To Obtain Acceptable Alignment On G-03 Lube Oil Circulation Pump

CR 01918667, 1P-11A As-found Coupling Gap Below RMP Requirements

CR 01919077, Adverse Trend - Engineering CAP Backlog

CR 01920608, Adverse Trend - Engineering CAP Backlog

CR 01920659, 1P-029 As-found Alignment Checks Were Outside the Acceptance Criteria of

RMP 9044-1

4

CR 01920783, During Performance of WO# 40241255 Checking Alignment on the Terry turbine

CR 01921089, Recent Decline In Operations Performance

CR 01922342, Increase In Initiation Rate of Anonymous and NSC ARs

CR 01924763, FA Errors & Less Than Adequate CAP Threshold

CR 01927436, 2P-11B Loose Hold Down Bolts And As-Found Alignment

CR 01932698, 95002 Wave Run-Up Protection May Conflict With Other Floods

CR 01936250, Employee Behavior Not Aligning With Expectations

CR 01936497, Conflict Between AOP-13C High Winds And PC 80 Part 7 Barrier

CR 01937027, 95002 Revise NP 7.5.2 and Form PBF-9178 to Address Flooding

CR 01937424, PBSA-ENG-15-01 External Events Program Quick Hit Assessment

CR 01938711, NRC 95002 Inspection - RCE 1883633 EOCA for CC2

NRC Identified CRs

CR 01938106, Incomplete Disposition of AR 01860140 On Unit 1 TDAFWP

CR 01938122, During NRC Walk Down Black Putty and Dry Boric Acid Was Noted on the Base

Plate of the Unit 2 Train B Containment Spray Pump

CR 01938271, Snow Was on the Barrier Installation Pads As Well As A Power Cable

CR 01938314, Visible Dimple Noted Near Jacking Bolt

CR 01938317, During Walk Down Dried Boric Acid Noted on The Unit 2 Train B RHR

Pump Seal

CR 01938326, Final Effectiveness Reviews for Common Cause 1 and 2 Were Inappropriately

Reliant Upon NRC Input

CR 01938384, Alignment Issue With Valve 2RH-823B Reach Rod

CR 01938501, Maximum Precipitation and Wave Run Up Not Assessed Simultaneously

CR 01938670, Root Cause Reports Were Not Aligned with the 95002 Procedure

CR 01938711, Scope for the Extent of Cause of Contributing Cause 2 From the Flooding RCE

Is Limited to NRC Concerns Only

CR 01938749, Attachment of Spring Cans to the MOVs After All As Left Testing Completed

CR 01938706, Formal Aggregate Review of all Flooding Related CRs

CR 01938825, Potential Storm Drain Bypass of Wave Run Up Barriers Not Assessed

CR 01938861, Risk Analysis Sections in Root and Common Causes Narrowly Focused

CR 01939011, Expand FSAR Section on Probable Maximum Precipitation Event

CR 01939095, VTM Dowling Recommendation Not Incorporated Into Procedures

CR 01939217, TDAFWP Root Cause Did Not Implement a Vendor Recommendation

CR 01939345, No Corrective Actions Initiated for Flooding Barriers During Cold Weather

CR 01939362, Functionality Assessments Found Issues But No Corrective Actions Taken

CR 01939389, Needed Enhancement to FSAR Appendix A.7, Internal Flooding

CR 01939838, Remove Door 349 When Wave Run Up Barriers Are Installed

CR 01940082, Procedure PC 80 Part 7, Revision 6 50.59 Screen Error

CR 01940118, Procedure PC 80 Part 7, Revision 4 50.59 Screen Error

CR 01940511, Errors Identified in Surveillance PBF-2124

CR 01940562, Poor CAP Product Quality

CR 01940606, Errors Identified in Procedure PC 80, Part 7

CR 01940621, FSAR Revision Required

CR 01940739, Unintentional Change to PC 80 Part 7 Identified

CR 01941022, Additional Errors Found in PBF-2124

CR 01941085, Potential Licensing Basis Questions Identified

CR 01941262, Quality Level of Flood Related Doors in Error

CR 01941902, Readiness for Inspection Letter Sent the Same Day as it Was Identified That the

Site was Not Ready for the Inspection

5

CR 01942059, Another Error Found In PBF-2124

CR 01942315, Several Drawing Errors Identified

CR 01942317, Error Identified On ARB C01 B1-1

CR 01942343, Error Identified In AOP-13C

CR 01943803, Use of Wrong NRC Cross Cutting Code in Effectiveness Review Criteria

CR 01946330, Severity Level IV Violation for 50.59 - Use of Roll-Up Doors

Drawings

M-1, Equipment Location Plan Containment Operating Floor Unit 1, Revision 19

M-3, Water Intake Facility General Arrangement Plan B-B, Revision, November 17, 1967

M-4, Water Intake Facility General Arrangement Plan C-C and D-D, November 17, 1967

M-15, Water Intake Facility Piping Section F-F, November 4, 1969

M-16, Circulating Water Pump House Piping, Revision 13

M-2007, Equipment Location Plan Ground Floor North, Revision 22

M-2009, Equipment Location Plan Sections H-H and K-K, Revision 9

M-2010, Equipment Location Miscellaneous Section, Revision 5

C-1, Site Plan, Revision 19

6704-E-121001, Plant Key Plan, Drawing, Index and Specification Numbers, Revision 4

6704-E-121102, Diesel Generator Building Floor and Roof Plan, Revision 5

6704-E-151001, Diesel Generator Building Yard Area Grading Plan, Revision 3

M-165, Turbine Building Floor & Equipment Drainage Area No 3 - Plan at EL. 8.0, Revision 6

Licensee Procedures

AD-AA-103, Nuclear Safety Culture Program, Revision 5

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 7

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 11

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 12

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 15

RMP 9044-1, Auxiliary Feedwater Pump Terry Turbine Overhaul, Revision 35

RMP 9376-1, Limitorque MOV Removal, Installation, SWAP, and Testing for Gate and

Globe Valves

RMP 9376-2, Limitorque MOV Static/DP Testing for Gate and Globe Valves

RMP 9376-3, Limitorque MOV Removal, Installation, and Adjustment for Butterfly Valves

RMP 9376-4, Limitorque Motor Operator Model SMB-000 Disassembly, Inspection Repair,

and Re-Assembly

RMP 9376-5, Limitorque Motor Operator Model SMB-0 Through SMB-4 Disassembly,

Inspection, Repair, and Re-Assembly

RMP 9376-6, Limitorque Motor Operator Model SMB-00 Disassembly, Inspection, Repair, and

Re-Assembly

RMP 9008-1, RHR Pump Removal and Installation

RMP 9005-2, SI Pump Overhaul

Vendor Manual 0501, Pacific Pumps, Inc.

AOP-13C; Abnormal Operating ProcedureSevere Weather Conditions, Revision 32

NP 7.5.2; PBNP Owner Controlled Area Temporary Structure Limitations, Revision 12

NA-AA-200, Employees Concern Program Process Description, Revision 5

PI-AA-01, Corrective Action Program and Condition Reporting, Revision 3

PI-AA-204, Condition Identification and Screening Process, Revision 22

PI-AA-205, Condition Evaluation and Corrective Action, Revision 23

PI-AA-100-1005, Root Cause Analysis, Revision 8

6

PI-AA-100-1006, Common Cause Evaluation, Revision 6

PI-AA-100-1007, Apparent Cause Analysis, Revision 7

PI-AA-100-1008, Condition Evaluation, Revision 5

PI-AA-101-1001, Quick Hit Assessments, Revision 5

MA-AA-203-1001, Work Order Planning, Revision 1

PDM 1.0, Vibration Monitoring Program

Procedure IT 02, High Head Safety Injection Pumps and Valves Train B, Unit 2

Procedure IT 03, Low Head Safety Injection Pumps and Valves Train A, Unit 1

Procedure IT 06, Containment Spray Pump and Valves

Procedure IT 12, 1P-11B, Component Cooling Water Pumps and Valves Unit 1

Procedure IT-07D, Service Water Pump (Quarterly) Surveillance

PC 80 Part 7, Lake Water Level Determination, Revision 3

PC 80 Part 7, Lake Water Level Determination, Revision 4

PC 80 Part 7, Lake Water Level Determination, Revision 5

PC 80 Part 7, Lake Water Level Determination, Revision 6

PC 80 Part 7, Lake Water Level Determination, Revision 7

PC 80 Part 7, Lake Water Level Determination, Revision 8

PC 80 Part 7, Lake Water Level Determination, Revision 9

PC 80 Part 7, Lake Water Level Determination, Revision 10

CL 11A G-02, G-02 Diesel Generator Checklist, Revision 29

NP 7.2.29; External Events Program, Revision 0

Root Cause Reports

RCE 01757131, Potential Violation Due to a Degraded Emergency Planning Risk Significant

Planning Standard Function, Revision 4

RCE 01768931, Unit 1 Turbine Driven Auxiliary Feedwater Pump 1P-29 Coupling Degraded

During IT-08A Run, Revision 5

RCE 01883633, Potential Greater Than Green Finding Flooding, Revision 3

RCE 01896156, Degraded Cornerstone - Mitigating Systems Two White Findings, Revision 1

Calculations

FPL-076-CALC-017, Maximum Precipitation Analysis for Past Reportability, Revision 0

CALC 2008-0024, AFWP Room Flood Basis CalculationJanuary 23, 2014, Revision 1

CALC 2009-0008, Circulating Water Pump House Internal Flooding, Revision 1

FPL-076-CALC-016, Flow Depth Sensitivity to Openings with Wave BarriersFebruary 6, 2014,

Revision 0

FPL-076-CALC-003, Point Beach DELFT3D Surge and Wave Model, Revision 0

EC 279455, Time Available to Respond to Threat From Rising Water, June 24, 2013

FPL-076-CALC-014, PBNP Precipitation and Snow Intensity Determination and Roof Drainage

Evaluation - December 18, 2013, Revision 0

FPL-076-CALC-015, Maximum Precipitation Flood Effects - January 7, 2014, Revision 0

CALC 2014-0002, Effects on Safety Equipment of Bypassing the Installed Wave Run-Up

Barriers Through The Storm Drains - February 11, 2014, Revision 0

Miscellaneous Documents

List of Technical Procedure Revisions for 2013

Presentation for Outage Review Board Team Meeting, February 4, 2014

Corrective Action Review Board Package for February 4, 2014

7

PBSA-PBNP-13-013, Quick Hit Assessment Report for the 95002 Mock Inspection for

Degraded Cornerstone, October 29, 2013

PBSA-ENG-07-13, 2008 Component Design Basis Inspection Preparations, March 10-20, 2008

PBSA-ENG-10-20, Focused Self-Assessment of Flooding Program, September 20-23, 2010

PBSA-ENG-11-01, Component Design Basis Inspection Preparations, January 17-27, 2011

PBSA-ENG-06-02, SA Preparation for Design Basis Inspection Based on 71111.21,

January 16 - February 2, 2006

PBSA-ENG-12-20, Quick Hit Assessment ReportFlooding Program, April 15 - May 24, 2013

PBSA-PBNP-13-02, CR 01908740, Quick Hit Assessment Report Station Nuclear Safety

Culture, September 23 through October 4, 2013

PBSA-PBNP-12-02, Quick Hit Assessment Report Station Nuclear Safety Culture

September 17 through 20, 2012

MOR 2013-23, Missed Opportunity ReviewPotential Greater Than Green FindingFlooding,

July 9, 2013

NOS Daily Quality Summary Related to Flooding MORGas Accumulation Management

Program, April 24, 2013

CEI Independent Evaluation, Point Beach Root Cause Evaluation for NRC White Performance

IndicatorFlooding, September 20, 2013

EC 280223, Review of Flooding Vulnerability Report for Possible CLB Encroachment,

October 22, 2013

NEE 05-PR-003, Flooding Vulnerability Report, Revision 0

EN-AA-203-1001 Operations TrainingOperability Determinations/Functionality Assessment

Training Materials, August 28, 2013

EN-AA-203-1001 Engineering Lesson PlanOperability Determinations/Functionality

Assessments, July 3, 2013

SCR 2013-0213, 50.59 Screening Form FSAR Sect 2.5 PMP FloodJanuary 28, 2014,

Revision 1

Monthly Weather ReviewThe Prediction of Surges in the Southern Basin of Lake Michigan;

May 1965

NPC98-00509, Harza Preliminary Hydrologic and Hydraulic Studies for Nuclear Power Plant

Site Selection, March 18, 1966

NOS Observations, October 30, 2008, November 20, 2009, August 16, 2010, April 23, 2011,

November 19, 2011

Point Beach Daily Quality Summary - 1P-29 Turbine Driven Auxiliary Feedwater Pump,

January 27, 2012

Point Beach Daily Quality Summary - Initial Auxiliary Feedwater Pump and Terry Turbine

Alignment, June 22, 2012

Point Beach Daily Quality Summary - Terry Turbine Oil Change and Sampling, July 02, 2012

PBN 12-010, Nuclear Oversight Report: Maintenance-Corrective and Preventative,

July 12, 2012

Point Beach Daily Quality Summary - 1/2 P-38 AFW Pump October 16, 2012

PBN-12-014, Nuclear Oversight Report: System Engineering, November 19, 2012

Point Beach Daily Quality Summary - 2P-29 TDAFW Pump Assembly, November 19, 2012

PBN-13-003 Nuclear Oversight Report: Engineering Design, March 8, 2013

Point Beach Daily Quality Summary - Fire Protection Walkdown P-53 Motor Driven Auxiliary

Feed Pump Rooms, October 2, 2013

MOR 2013-09 Missed Opportunity Review, 1-29-T, Auxiliary Feed Water Pump Turbine

Coupling Failure, CR 1846183, February 7, 2014

WO 383111-01, STP-00014; Inspect for License Renewal per LR-TR-519, May 17, 2010

WO 40188994-09, Simulate PC 50 Part 7 Draft with New Barriers (PMT), November 21, 2013

WO 40188994-04, Verify Ability to Place and Secure Jersey Barriers (PMT), July 10, 2013

8

Fleet Daily Quality Summary ReportFukushima, November 22, 2011

Point Beach Daily Quality Summary ReportFlooding Related, April 4, 2012

Point Beach Nuclear Oversight ReportFire Protection and Flood Doors, October 7, 2010

Point Beach Nuclear Oversight ReportISFSI Environmental Impacts Audit, July 14, 2011

Point Beach Nuclear Oversight ReportReview of OE Related to Flooding and Actions Taken,

March 8, 2013

Point Beach Nuclear Oversight ReportReview of CommitmentsFlooding Walk Downs,

March 30, 2013

Fleet Daily Quality Summary ReportFlooding Underground Cables, January 21, 2008

WO 40220319-01, PC 80 Part 7 Install CWPH Concrete Block Barriers, February 4, 2014

Pictures of Wave Barriers Constructed, November 26, 2013

9

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access Management System

AFW Auxiliary Feedwater

AR Action Request

CAPR Corrective Action to Prevent Recurrence

CC Contributing Cause

CCA Common Cause Analysis

CCDP Conditional Core Damage Probability

CDF Core Damage Frequency

CFR Code of Federal Regulations

CLB Current License Basis

CR Condition Report

CW Circulating Water

CWPH Circulating Water Pump House

CY Calendar Year

DRP Division of Reactor Projects

EFR Effectiveness Review

EJ Expansion Joint

EP Emergency Preparedness

EPRI Electric Power Research Institute

FA Functionality Assessment

FP Fire Protection

FSAR Final Safety Analysis Report

gpm Gallons per Minute

HCLPF High Consequence of Low Probability of Failure

HEP Human Error Probability

IMC Inspection Manual Chapter

INPO Institute of Nuclear Power Operations

IP Inspection Procedure

IPEEE Individual Plant Examination External Events

IR Inspection Report

IST In-service Test

KSA Knowledge Skills and Abilities

LERF Large Early Release Frequency

LOCA Loss of Coolant Accident

LOOP Loss of Off-Site Power

MOV Motor Operated Valve

N/A Not Applicable

NCV Non-Cited Violation

NOV Notice of Violation

NRC U.S. Nuclear Regulatory Commission

OEM Original Equipment Manufacturer

OSHA Occupational Safety Health and Safety

PARS Publicly Available Records

PC Procedure Call-Up

PMP Probable Maximum Precipitation

PMT Post Maintenance Test

PRA Probabilistic Risk Assessment

PWR Pressurized Water Reactor

RASP Risk Assessment Standardization Project

10

RC Root Cause

RCE Root Cause Evaluation

ROP Reactor Oversight Process

SCWE Safety Conscience Work Environment

SDP Significance Determination Process

SME Subject Matter Expert

SPAR Standardized Plant Analysis Risk

SQAC Significant Condition Adverse to Quality

SRA Senior Reactor Analyst

SW Service Water

TDAFWP Turbine Driven Auxiliary Feedwater Pump

TB Turbine Building

TS Technical Specification

URI Unresolved Item

VTM Vendor Technical Manual

Yr Year

WO Work Order 11

E. McCartney -3-

previous terminology will be converted to the latest revision in accordance with the

cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for

cross-cutting themes and potential substantive cross-cutting issues in accordance with

IMC-0305 starting with the CY 2014 mid-cycle assessment review.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure, and your response (if any) will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Anne T. Boland, Director

Division of Reactor Projects

Docket Nos. 50-266; 50-301

License Nos. DPR-24; DPR-27

Enclosure:

IR 05000266/2014007; 05000301/2014007

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServTM

Distribution:

See next page

DOCUMENT NAME: PB 2014 007

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII RIII RIII

NAME BBartlett:mt/rj JCameron

BBartlett for

DATE 04/27/14 04/27/14

OFFICIAL RECORD COPY

Letter to Eric McCartney from Ann Boland dated March 28, 2014

SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

NRC 95002 SUPPLEMENTAL INSPECTION REPORT

05000266/2014007; 05000301/2014007

DISTRIBUTION:

Ernesto Quinones

RidsNrrDorlLpl3-1 Resource

RidsNrrPMPointBeach

RidsNrrDirsIrib Resource

Cynthia Pederson

Darrell Roberts

Steven Orth

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

Patricia Buckley

ROPassessment.Resource@nrc.gov