ML113180464

IR 05000261-11-004, 05000261-11-502, on 07/01/2011 - 09/30/2011, H.B. Robinson Steam Electric Plant, Unit 2, Adverse Weather Protection and Operability Evaluations

ML113180464
Person / Time
Site:	Robinson
Issue date:	11/14/2011
From:	Randy Musser NRC/RGN-II/DRP/RPB4
To:	William Gideon Carolina Power & Light Co
References
IR-11-004, IR-11-502
Download: ML113180464 (35)

See also: IR 05000261/2011502

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

November 14, 2011

Carolina Power and Light Company

ATTN: Mr. William R. Gideon

Vice President - Robinson Plant

H. B. Robinson Steam Electric Plant

Unit 2

3581 West Entrance Road

Hartsville, SC 29550

SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED

INSPECTION REPORT 05000261/2011004, 05000261/2011502, AND

ASSESSMENT FOLLOW-UP LETTER

Dear Mr. Gideon:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your H.B. Robinson reactor facility. The enclosed integrated inspection report

documents the inspection results, which were discussed on November 14, with Mr. Thomas

Cosgrove and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

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

personnel.

The report documents one self-revealing apparent violation (AV) that has potential safety

significance greater than very low safety significance. The significance of this finding is

designated as To Be Determined (TBD) until the safety characterization has been completed.

This finding is associated with the failure to consider how the aggregate changes to the sites

topography could impact the sites ability to drain storm water runoff and adequately respond to

localized flooding during periods of heavy rain. However, the plant has taken appropriate

interim corrective actions such that the finding does not present an immediate safety concern.

Immediate actions taken by your staff included the removal of the water from the affected plant

buildings and grounds. In addition, within a few weeks of the event, the licensee repaired the

washed out area of the berm just to the north of the power block, and performed interim

adjustments to site topography to limit ponding near the berm.

In addition, the report documents one NRC-identified finding of very low safety significance

(Green). The finding was determined to involve a violation of NRC requirements. However,

because of the very low safety significance and because it is entered into your corrective action

program, the NRC is treating this finding as non-cited violation (NCV) consistent with Section

2.3.2 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response

CP&L 2

within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with

copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the H.B. Robinson facility.

On June 9, 2011, the NRC conducted an exit for the IP 95002 supplemental inspection which

was conducted for the three White findings, which placed H.B. Robinson Unit 2 in the Degraded

Cornerstone Column in the third quarter of 2010, as discussed in the assessment letter dated

March 4, 2011. On July 6, 2011, the NRC issued the supplemental inspection report (IR 5000261/2011010, ML # 111870510), which documented that you adequately addressed the

three White findings. As stated in the supplemental inspection report, one finding, specifically

05000261/2010013-01, Failure to Comply with Conduct of Operations Procedure, would still be

considered for agency actions in accordance with the Action Matrix until September 30, 2011.

The NRC determined that as of October 1, 2011, the performance at H.B. Robinson Unit 2 is in

the Licensee Response Column of the Reactor Oversight Process Action Matrix. Although plant

performance is now considered to be within the Licensee Response Column, the NRC has not

yet finalized the significance of apparent violation AV 05000261/2011004-01, Water Intrusion

into Safety-Related Buildings due to Inadequate Design of Site Storm Water Runoff Drainage

System. The final safety significance determination of this issue may change our assessment of

the performance at H.B. Robinson Unit 2.

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

and its enclosure will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's document

system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Randall A. Musser, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Docket No.: 50-261

License No.: DPR-23

Enclosure: Inspection Report 05000261/2011004, 05000261/2011502

w/Attachment: Supplemental Information

cc w\encl: See page 3

__ML113180464____________ X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED

OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRS

SIGNATURE JGW1 by email /NA/ JAH5 by email CBS by email ETC1 by email JDA by email MSC2 by email

NAME JWorosilo JDodson JHickey CScott ECoffman JAustin MCoursey

DATE 11/14/2011 11/ /2011 11/03/2011 11/14/2011 11/14/2011 11/03/2011 11/14/2011

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

OFFICE RII:DRS RII:DRP RII:DRP

SIGNATURE CRS1 by email TEC1 by email RAM

NAME CStancil TChandler RMusser

DATE 11/03/2011 11/04/2011 11/14/2011 11/ /2011 11/ /2011

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

CP&L 3

cc w/encl: Richard Haynes

Division of Radiological Health Director, Division of Waste Management

TN Dept. of Environment & Conservation Bureau of Land and Waste Management

401 Church Street S.C. Department of Health and

Nashville, TN 37243-1532 Environmental Control

Electronic Mail Distribution

Sandra Threatt, Manager

Nuclear Response and Emergency Kelvin Henderson

Environmental Surveillance General Manager

Bureau of Land and Waste Management Nuclear Fleet Operations

Department of Health and Environmental Progress Energy

Control Electronic Mail Distribution

Electronic Mail Distribution

Thomas Cosgrove

Robert J. Duncan II Plant General Manager

Vice President H.B. Robinson Steam Electric Plant, Unit 2

H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy

Progress Energy Electronic Mail Distribution

Electronic Mail Distribution

Donna B. Alexander

Brian C. McCabe Manager, Nuclear Regulatory Affairs

Manager, Nuclear Oversight (interim)

Shearon Harris Nuclear Power Plant Progress Energy

Progress Energy Electronic Mail Distribution

Electronic Mail Distribution

Robert P. Gruber

Scott D. West Executive Director

Superintendent Security Public Staff - NCUC

H. B. Robinson Steam Electric Plant 4326 Mail Service Center

Progress Energy Raleigh, NC 27699-4326

Electronic Mail Distribution

W. Lee Cox, III

Joseph W. Donahue Section Chief

Vice President Radiation Protection Section

Nuclear Oversight N.C. Department of Environmental

Progress Energy Commerce & Natural Resources

Electronic Mail Distribution Electronic Mail Distribution

David T. Conley Greg Kilpatrick

Senior Counsel Operations Manager

Legal Department H.B. Robinson Steam Electric Plant, Unit 2

Progress Energy Progress Energy

Electronic Mail Distribution Electronic Mail Distribution

John H. O'Neill, Jr. cc w/encl. (continued next page)

Shaw, Pittman, Potts & Trowbridge

2300 N. Street, NW

Washington, DC 20037-1128

CP&L 4

cc w/encl. (continued) John W. Flitter

Mark Yeager Director of Electric & Gas Regulation

Division of Radioactive Waste Mgmt. South Carolina Office of Regulatory Staff

S.C. Department of Health and Electronic Mail Distribution

Environmental Control

Electronic Mail Distribution

Public Service Commission

State of South Carolina

P.O. Box 11649

Columbia, SC 29211

Chairman

North Carolina Utilities Commission

Electronic Mail Distribution

Henry Curry

Training Manager

H.B. Robinson Steam Electric Plant, Unit 2

Progress Energy

Electronic Mail Distribution

Senior Resident Inspector

U.S. Nuclear Regulatory Commission

H. B. Robinson Steam Electric Plant

2112 Old Camden Rd

Hartsville, SC 29550

William R. Gideon

Director Site Operations

H. B. Robinson Steam Electric Plant, Unit 2

Progress Energy

Electronic Mail Distribution

Christos Kamilaris

Manager, Support Services

H.B. Robinson Steam Electric Plant, Unit 2

Progress Energy

Electronic Mail Distribution

Rich Rogalski

Supervisor, Licensing/Regulatory Programs

H. B. Robinson Steam Electric Plant

Electronic Mail Distribution

CP&L 5

Letter to William R. Gideon from Randall A. Musser dated November 14, 2011

SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED

INSPECTION REPORT 05000261/2011004, 05000261/2011502, AND

ASSESSMENT FOLLOW-UP LETTER

Distribution w/encl:

C. Evans, RII EICS

L. Douglas, RII EICS

OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMRobinson Resource

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No: 50-261

License No: DPR-23

Report No: 005000261/2011004, 05000261/2011502

Facility: H. B. Robinson Steam Electric Plant, Unit 2

Location: 3581 West Entrance Road

Hartsville, SC 29550

Dates: July 1, 2011 through September 30, 2011

Inspectors: J. Hickey, Senior Resident Inspector

T. Chandler, Acting Senior Resident Inspector

C. Scott, Resident Inspector

E. Coffman, Resident Inspector, V.C. Summer

M. Coursey, Reactor Inspector

C. Stancil, Resident Inspector, Browns Ferry

J. Austin, Senior Resident Inspector, Harris

Approved by: R. Musser, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000261/2011004, 05000261/2011502, 07/01/2011 - 09/30/2011; H.B. Robinson Steam

Electric Plant, Unit 2; Adverse Weather Protection and Operability Evaluations.

The report covered a three month period of inspection by several resident inspectors and one

reactor inspector. One AV and one NCV were identified. The significance of most findings is

indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects were determined

using IMC 0310, Components within the Cross-Cutting Areas. Findings for which the SDP

does not apply may be Green or be assigned a severity level after NRC management review.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Initiating Events

• TBD. A self-revealing apparent violation (AV) of 10 CFR 50, Appendix B, Criterion III,

Design Control, was identified for the licensees failure to consider how the aggregate

changes to the sites topography could impact the sites ability to drain storm water

runoff and adequately respond to localized flooding during periods of heavy rain. This

resulted in the ponding of storm water runoff, the subsequent direction of runoff flow

towards the power block, overfilling of the retention basin, backup of the storm drainage

system, and ultimately, uncontrolled water intrusion into safety-related equipment rooms

in the auxiliary building. The licensee took immediate actions to remove the water from

the affected plant buildings and grounds. In addition, within a few weeks of the event,

the licensee repaired the washed out area of the berm just to the north of the power

block, and performed interim adjustments to site topography to limit ponding near the

berm. The licensee plans to perform additional site grade and trench restoration and

remediation to permanently prevent site ponding. This issue was entered into the

licensees corrective action program as NCR 468235.

The licensees failure to consider how the aggregate changes to the sites topography

could impact the sites ability to drain storm water runoff and adequately respond to

localized flooding during periods of heavy rain as required by procedure EGR-NGGC-

0005, Engineering Change, was a performance deficiency. This performance

deficiency was considered more than minor because it was associated with the Initiating

Events Cornerstone attributes of the Design Control (plant modifications) and Protection

Against External Factors (flood hazard), and adversely affected the cornerstone

objective to limit the likelihood of those events that upset plant stability and challenge

critical safety functions during shutdown as well as power operations. Specifically, the

failure to consider aggregate changes to the sites topography on the sites ability to

drain storm water runoff resulted in uncontrolled water intrusion into safety-related

equipment rooms. The inspectors assessed the finding using Inspection Manual

Chapter (IMC) 0609, Significance Determination Process (SDP), Att. 4, Phase 1 - Initial

Screening and Characterization of Findings, and determined the finding was potentially

greater than very low safety significance because the finding increases the likelihood of

an external flooding event. As a result, the characterization worksheet for Initiating

Events required a Phase 3 analysis using the Individual Plant Examination for External

Enclosure

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Event Submittal (IPEEE) or other existing plant specific analyses as inputs. The

significance of this finding is designated as To Be Determined (TBD) until the safety

characterization has been completed by the NRC Senior Reactor Analyst (SRA). The

inspectors determined that the cause of this finding was related to the trending and

assessment aspect in the Corrective Action Program component of the Problem

Identification and Resolution cross-cutting area. (P.1(b)) (Section 1R01)

Cornerstone: Mitigating Systems

• Green. The inspectors identified a Green NCV of Technical Specification (TS) 5.4.1,

Administrative Controls, Procedures, for failure to establish procedural guidance to

monitor Service Water System (SWS) parameters and operate the SWS strainers

following a loss of offsite power (LOOP). Following a LOOP, the operators ability to

recover from a plugged SWS strainer would be impacted due to the loss of the

associated control alarm and the lack of procedural guidance to manually operate the

SWS strainers. The licensee has revised plant procedures to include additional

instructions that will ensure that operators can recover from plugged SWS strainers and

preserve the operation of the SWS following a LOOP. This issue was entered into the

licensees corrective action program as NCR 473900.

The failure to establish procedural guidance to locally monitor SWS parameters and

manually operate the SWS strainers following a LOOP was a performance deficiency.

This issue was more than minor because if left uncorrected this finding would have the

potential to lead to a more significant safety concern. Specifically, the inability to clean

the service water strainers, following a prolonged LOOP, could impact the operation of

the service water system. The SDP Phase 1 screening determined that this finding was

within the mitigating systems cornerstone and was potentially risk significant due to a

seismic, flooding or severe weather initiating event and therefore required a Phase 3

SDP analysis. An NRC Senior Reactor Analyst (SRA) determined the lack of procedure

for a loss of the service water strainers due to an external event (i.e., loss of offsite

power removing power to the strainers and causing debris to clog the system) was of

very low risk significance i.e., Green. The main contributors to the low risk results were:

1) the low likelihood of a total loss of service water event, and 2) the probability of

recovery of the strainers and/or the system despite the lack of procedures. The

inspectors determined that the finding has a cross-cutting aspect in the Corrective Action

Program component of the Problem Identification and Resolution area, because the

licensee failed to thoroughly evaluate the issue such that the resolution addressed the

cause and extent of conditions, as necessary. Specifically, licensees evaluation of the

NCR associated with the lack of plant procedures to manually operate the SWS, failed to

recognize that the control room indication associated with a plugged SWS strainer would

be lost following a LOOP. (P.1(c)) (Section 1R15)

B. Licensee-Identified Violations

None

Enclosure

REPORT DETAILS

Summary of Plant Status: The unit began the inspection period at rated thermal power. On

July 22 a power reduction to 50 percent was initiated for planned maintenance. The unit was

returned to rated thermal power on July 25, 2011. On August 2 power management actions

began in order to control circulating water discharge temperature into Lake Robinson. These

actions resulted in power being cycled by as much as 20 percent and continued until August 15.

The unit operated at full power until September 26 when it tripped due to a failed relay in the C

Reactor Coolant Pump (RCP) breaker. Startup of the unit was initiated on September 29 and

rated thermal power was attained on October 1.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 External Flooding

(Closed) URI 05000261/2011003-1, Rainstorm Results in Flooding of the Power Block

a. Inspection Scope

The inspectors previously opened URI 05000261/2011003-01, Rainstorm Results in

Flooding of the Power Block, in NRC Integrated Inspection Report 05000261/2011003.

The inspectors performed a review of the Updated Final Safety Analysis Report

(UFSAR), the IPEEE, the root cause evaluation report for NCR 468235, and calculation

RNP-F/PSA-0009, Assessment of Internally Initiated Flood Events.

b. Findings

Introduction. A self-revealing apparent violation (AV) of 10 CFR 50, Appendix B,

Criterion III, Design Control, was identified for the licensees failure to consider how the

aggregate changes to the sites topography could impact the sites ability to drain storm

water runoff and adequately respond to localized flooding during periods of heavy rain.

This performance deficiency resulted in the ponding of storm water runoff, the

subsequent direction of runoff flow towards the power block, overfilling of the retention

basin, backup of the storm drainage system, and ultimately, uncontrolled water intrusion

into safety-related equipment rooms in the auxiliary building. The licensee took

immediate actions to remove the water from the affected plant buildings and grounds. In

addition, within a few weeks of the event, the licensee repaired the washed out area of

the berm just to the north of the power block, and performed interim adjustments to site

topography to limit ponding near the berm. The licensee plans to perform additional site

grade and trench restoration and remediation to permanently prevent site ponding. This

issue was entered into the licensees corrective action program as NCR 468235.

Description. The UFSAR for the H.B. Robinson Plant states: Flooding is a physical

impossibility at this site since the maximum cooling lake level which can be maintained

by the drain and appurtenant structures is below plant grade. The IPEEE for the plant

Enclosure

5

states that due to the sites topography, the probability of a sustained water level of one

foot or more at the Auxiliary Building following the probable maximum precipitation (30

inches in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - NOAA 1978) is extremely unlikely. On May 27, 2011, the Robinson

Nuclear Plant experienced a heavy rainstorm that resulted in uncontrolled water

intrusion into several safety-related equipment rooms due to external flooding. This

storm produced only 3.71 inches of rain in one 6-hour period, which is only 12 percent of

that assumed in the IPEEE.

The heavy rains caused localized ponding of storm water runoff in the protected area

(PA) and outlying areas of the owner controlled area. From approximately 1200 on May

27, 2011, to 0200 on May 28, 2011, the plant received a total of 5.82 inches of rain, with

3.71 inches being received in the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This initial influx of rain water exceeded

the capacity of the existing storm drain system, and as a result, storm water backed up

into plant buildings, including the A train emergency diesel generator (EDG) room. The

floor drains in the EDG rooms, which are tied directly to the storm drain system, had

been modified in 1994 to add back-flow isolation valves to prevent such an event.

However the back-flow isolation valve in the A EDG room failed to close.

Within the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, storm water runoff from the areas north of the plant, which

include the Independent Spent Fuel Storage Installation (24P-ISFSI) pad, the Unit 1

landfill, and the Unit 1 coal pile, began to form a large pond on the north side of the berm

which runs along the protected area (PA) fence on the north side of the plant. At

approximately 1515 on May 27 the first washout of soil occurred from the berm area

south of the ISFSI pad. The washed out soil collected in the storm drains and storm

drain catch basins on the north side of the plant rendering them inoperable. As a result,

several of the buildings on the north side of the power block were flooded with several

inches of water.

At 1530, another larger washout of the same berm occurred in the southeast corner of

the 24P-ISFSI pad allowing additional amounts of soil and storm water runoff to drain

into the north side of the PA. This second washout effectively drained the large pond

north of the berm. Soon after, a third washout occurred in the southwest corner of the

24P-ISFSI pad.

By 1800, the licensee had removed enough soil from the north side of the plant to allow

the 6-8 inches of water that had accumulated up against the power block to drain to the

retention ponds. This draining of the north plant area eventually overflowed both the

Unit 1 (coal plant) and Unit 2 retention basins which had been cross-connected earlier in

an attempt to prevent Unit 2 retention basin from overflowing.

It should be noted that none of the Auxiliary Building internal or external doors are

designed to be watertight, and as a result, water flowed under and around the external

doors on the north and east sides of the building for several hours. However, the

Auxiliary Building sump system minimized the effects of the water ingress until the sump

pumps had to be secured due to high level in the Waste Hold Up Tank. The water level

in the Safety Injection and Containment Spray pump room, which is located against the

north wall of the Auxiliary Building, reached 1-2 inches in depth. Many rooms inside the

Auxiliary Building, including the A EDG room and the hallway that contains one of the

Enclosure

6

two safety-related 480 volt ac motor control centers, had 1-2 inches of water on the

floor. The Hot Machine Shop and New Fuel Storage Room, which are located on the

north side of the power block, contained 6-8 inches of standing water.

Within a few hours, the licensee had removed the water from the affected plant buildings

and grounds. In addition, within a few weeks of the event the licensee repaired the

washed out area of the berm and performed interim adjustments to site topography to

limit ponding near the berm. The licensee plans to perform additional site grade and

trench restoration and remediation to permanently prevent site ponding. The licensee

also initiated revisions to procedures to provide adequate guidance for slope and berm

backfill, coordinate site topography changes between Units 1 and 2, and to require

erosion control plans for parking areas, roadways, and drives.

The modifications to the sites topography that led to the May 27, 2011, external flooding

event occurred over several decades, but culminated with the capping of the Unit 2

landfill in April 2010. During the summer of 2010 there were three separate rain events

that caused breaches through the berm on the north side of the PA due to ponding of

storm water runoff. Therefore it can be conservatively assumed that the site was

vulnerable to external flooding events for approximately 13 months before the May 27

event.

Although no safety-related equipment was directly impacted during the May 27 event,

there were 1-2 inches of water in several rooms that contain significant amounts of

safety-related equipment. The majority of the safety-related equipment is mounted

approximately 12 inches above the floor. However, the rain storm on May 27 produced

only 3.71 inches of rain in one 6-hour period, which is only 12 percent of that assumed in

the IPEEE. Had the site received the probable maximum precipitation, the likelihood of

safety related equipment being impacted by raising flood water would have increased.

Analysis. The licensees failure to consider how the aggregate changes to the sites

topography could impact the sites ability to drain storm water runoff and adequately

respond to localized flooding during periods of heavy rain as required by procedure

EGR-NGGC-0005, Engineering Change, was a performance deficiency. Specifically,

the licensee did not follow procedure EGR-NGGC-0005, Engineering Change, which

provides guidance and checklist items to ensure that the aggregate effects of facility

changes on rain water runoff were considered. This performance deficiency was

considered more than minor because it was associated with the Initiating Events

Cornerstone attributes of the Design Control (plant modifications) and Protection Against

External Factors (flood hazard), and adversely affected the cornerstone objective to limit

the likelihood of those events that upset plant stability and challenge critical safety

functions during shutdown as well as power operations. Specifically, the failure to

consider aggregate changes to the sites topography on the sites ability to drain storm

water runoff resulted in uncontrolled water intrusion into safety-related equipment rooms.

The inspectors assessed the finding using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process (SDP), Att. 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined the finding was potentially greater than

very low safety significance because the finding increases the likelihood of an external

flooding event. As a result, the characterization worksheet for Initiating Events required

Enclosure

7

a Phase 3 analysis using the IPEEE or other existing plant specific analyses as inputs.

The significance of this finding is designated as To Be Determined (TBD) until the safety

characterization has been completed.

The inspectors determined that the cause of this finding was related to the trending and

assessment aspect in the Corrective Action Program component of the Problem

Identification and Resolution cross-cutting area. Specifically, the licensee used less-

than-adequate trending and assessment techniques and thus failed to recognize a

significant number of event pre-cursors that indicated an adverse trend in the sites

ability to control storm water runoff. P.1(b)

Enforcement. 10 CFR 50, Appendix B, Criterion III requires in part that the design basis

is correctly translated into drawings and procedures, and the adequacy of design

changes are verified or checked. Site procedure EGR-NGGC-0005, Engineering

Change, is used to implement this regulatory requirement. Contrary to the above, from

November 1966 to April 2010 the licensee made several modifications to the sites

topography without performing adequate design reviews that would have identified the

aggregate effects of the proposed topography changes on storm water runoff. This

resulted in the May 27, 2011, uncontrolled water intrusion into safety-related equipment

rooms. This issue was entered into the licensees corrective action program as NCR

468235. The licensee has initiated the following corrective actions to restore

compliance:

• Implement an Engineering Change to restore grading and trenching to ensure storm

runoff in the north plant area is directed to appropriate drains

• Perform necessary design basis calculations to support compliance with 10 CFR 50,

Appendix A, Criterion 2, Design bases for protection against natural phenomena

• Revise the interface agreement between Unit 1 and Unit 2 to coordinate changes to

the sites topography controlled by Unit 1 to ensure review by Unit 2 engineering for

impact to design, licensing, and regulatory requirements

• Revise the sites design change procedures to require a sedimentation and erosion

control plan when the potential for runoff of disturbed land exists

Pending determination of safety significance, this finding is identified as an apparent

violation (AV)05000261/2011004-01, Water Intrusion into Safety-Related Buildings due

to Inadequate Design of Site Storm Water Runoff Drainage System.

URI 05000261/2011003-01, Rainstorm Results in Flooding of the Power Block is closed.

Enclosure

8

1R04 Equipment Alignment

a. Inspection Scope

Partial System Walkdowns:

The inspectors performed the following three partial system walkdowns, while the

indicated structures, systems, and/or components (SSCs) were out-of-service for

maintenance and testing:

• 'B' motor-driven auxiliary feed water (AFW) pump while 'A' pump was out of service

for planned maintenance

• A Instrument Air System while B Instrument Air Compressor was out of service for

corrective maintenance

• A, B, and C safety injection (SI) pumps after the B and C SI pumps were

swapped following a test of the B SI pump

To evaluate the operability of the selected trains or systems under these conditions, the

inspectors compared observed positions of valves, switches, and electrical power

breakers to the procedures and drawings listed in the Attachment.

The inspectors reviewed the following ARs associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 477699, Moisture Separator Reheat Purge Valves Found Closed During Normal

Plant Operation

• 480007, Clearance Information Tags Hung on Wrong Components

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Resident Inspector Tours

a. Inspection Scope

For the five areas identified below, the inspectors reviewed the control of transient

combustible material and ignition sources, fire detection and suppression capabilities,

fire barriers, and any related compensatory measures to verify that those items were

consistent with Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire

Protection System, and UFSAR Appendix 9.5.A, Fire Hazards Analysis. The inspectors

walked down accessible portions of each area and reviewed results from related

surveillance tests to verify that conditions in these areas were consistent with

descriptions of the areas in the UFSAR. Documents reviewed are listed in the

Attachment.

Enclosure

9

The following areas were inspected:

• Turbine Building Ground Level (fire zones 25 A&B)

• Turbine Building Mezzanine Level (fire zones 25 E&F)

• 'A' and 'B' Battery Room (fire zone 16)

• Safety Injection Pump Room (fire zone 3)

• Component Cooling Water Pump Room (fire zone 5)

The inspectors reviewed the following AR associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 486287, Engine Driven Fire Pump Heaters Not Working

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

To evaluate the readiness of personnel to prevent and fight fires, the inspectors

observed fire brigade performance during the announced fire drill in the condensate

polishing building motor-control center on September 7. This included observing the pre-

drill briefing for the drill controllers, dress out of the fire brigade members in the fire

locker, fire brigade performance at the fire scene, and the post-drill critiques for the

controllers and the fire brigade. The inspectors evaluated the fire brigade performance

to verify that they responded to the fire in a timely manner, donned proper protective

clothing, used self-contained breathing apparatus, and had the equipment necessary to

control and extinguish the fire. The inspectors also assessed the adequacy of the fire

brigades fire fighting strategy including entry into the fire area, communications, search

and rescue, and equipment usage.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors walked down the SI pump room and the A emergency diesel generator

(EDG) room to verify that each area configuration, features, and equipment functions

were consistent with the descriptions and assumptions used in Calculation RNP-F/PSA-

0009, Assessment of Internally Initiated Flood Events. Specifically, motor controllers

and terminal boxes that could become potentially submerged were inspected to ensure

that the sealing gasket material was intact and undamaged. Those rooms were selected

Enclosure

10

because they contain risk-significant SSCs which are susceptible to flooding from

postulated pipe breaks. The inspectors also reviewed the operator actions credited in

the analysis to verify that the desired results could be achieved using the plant

procedures listed in the Attachment.

The inspectors reviewed the following ARs associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 482434, Potential Adverse Trend in Rainwater Intrusion

• 476676, Water Present In Manholes M-35 and M-36

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

The inspectors observed licensed-operator performance during requalification simulator

training to verify that operator performance was consistent with expected operator

performance, as described in Exercise Guide LOCT 03-4. This training tested the

operators ability to operate components from the control room, direct auxiliary operator

actions, and determine the appropriate emergency action level classifications while

responding to a turbine first stage pressure transmitter failure, manual control of steam

generator levels, a rod control urgent failure alarm, inadvertent turbine trip/reactor trip

and a loss of the E-2 safety bus with a failure of the B EDG output breaker to close.

The inspectors focused on clarity and formality of communication, the use of procedures,

alarm response, control board manipulations, group dynamics, and supervisory

oversight.

The inspectors also observed the simulator exercise freeze critiques to verify that the

licensee identified deficiencies and discrepancies that occurred during the simulator

training.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the three degraded SSC/function performance problems or

conditions listed below to verify the appropriate handling of these performance problems

or conditions in accordance with 10 CFR 50, Appendix B, Criterion XVI, Corrective

Action, and 10 CFR 50.65, Maintenance Rule. Documents reviewed are listed in the

Attachment.

Enclosure

11

The problems/conditions and their corresponding ARs were:

• 474815, C Charging Pump Flow in the Alert Range

• 478069, Right Turbine Stop Valve Did Not Go Completely Closed During Testing

• Overall Performance History of the Dedicated Shutdown Diesel System

During the reviews, the inspectors focused on the following:

• Appropriate work practices,

• Identifying and addressing common cause failures,

• Scoping in accordance with 10 CFR 50.65(b),

• Characterizing reliability issues (performance),

• Charging unavailability (performance),

• Trending key parameters (condition monitoring),

• 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and

• Appropriateness of performance criteria for SSCs/functions classified (a)(2) and/or

appropriateness and adequacy of goals and corrective actions for SSCs/functions

classified (a)(1).

The inspectors reviewed the following ARs associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 434642, Iso-Phase Bus Loss of Cooling Alarms Spuriously

• 434646, Steam Generator Feedwater Regulating Valves are Moving in a Jerking

Motion

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

For the six samples listed below, the inspectors reviewed risk assessments and related

activities to verify that the licensee performed adequate risk assessments and

implemented appropriate risk-management actions when required by 10 CFR

50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk

was promptly assessed, and that appropriate risk-management actions were promptly

implemented. Documents reviewed are listed in the Attachment. Those periods

included the following:

• July 1, 2011, Emergent work to repair the A and B Charging pump following failure

of the B Speed Controller and High Stuffing Box Temperature on A Charging Pump

Enclosure

12

• July 4-11, 2011, Work week included B Charging Pump maintenance, calibration of

the Refueling Water Storage Tank (RWST) Level Transmitter LT-948, and A

Instrument Air Compressor maintenance.

• July 11-17, 2011, Work week included V2-16C AFW Isolation Valve control switch

replacement, clean and test the B AFW Pump Oil Cooler, and inspection and

vibration monitoring of containment cooling fans

• July 25-31, 2011, Work week included B SI Pump stud inspection, SI room cooling

fan HVH-6A inspection, and testing of the A Containment Spray (CS) Pump

• August 1-7, 2011, Work week included an unplanned down-power to maintain water

discharge temperatures, reactor coolant pump seal injection flow transmitter

calibrations, and C Charging Pump scoop tube adjustment

• September 12-19, 2011, Work week included modifications to the Dedicated

Shutdown Diesel Generator and associated load center, and reactor protection

system train B logic testing.

The inspectors reviewed the following ARs associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 479209, Several PM Frequencies do not Align with Train Separation

• 476370, B MDAFW Pump Scheduled Unavailability Time Exceeded

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the four operability determinations associated with the ARs

listed below. The inspectors assessed the accuracy of the evaluations, the use and

control of any necessary compensatory measures, and compliance with the TS. The

inspectors verified that the operability determinations were made as specified by

Procedure OPS-NGGC-1305, Operability Determinations. The inspectors compared the

justifications provided in the determinations to the requirements from the TS, the

UFSAR, and associated design-basis documents to verify that operability was properly

justified and the subject components or systems remained available, such that no

unrecognized increase in risk occurred:

• 474425, B Charging Pump Speed Control Failed High

• 485071, A train SI Accumulator leaking

Enclosure

13

• 463149, Manual Operation of the Service Water Header Strainers

• 463429, Small Service Water Leak at SW-56 (Station Air Compressor Outlet to

Aftercooler)

Documents reviewed are listed in the Attachment.

The inspectors reviewed the following ARs associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 482618, MCC-6(10F)-42/C Pick Up Voltage Greater Than Procedure Threshold

• 483178, Inadequate Heat Removal During Station Battery Capacity Test

b. Findings

Introduction: The inspectors identified a green NCV of Technical Specification 5.4.1,

Administrative Controls, Procedures, for the licensees failure to establish adequate

procedural guidance to monitor SWS parameters and operate the SWS strainers

following a loss of offsite power (LOOP).

Description: On May 4, 2011, site engineering wrote a condition report, NCR 463149,

which identified that plant procedures did not include instructions to manually clean the

SWS strainers following a LOOP. The NCR noted that the SWS design bases document

validation report identified that the periodic cleaning of the SWS strainers had to be

performed using manual operator action following a LOOP. The vendor technical

manual outlines the procedure for the manual operation of the strainer. However,

current licensee procedures did not include instructions for operators to manually

operate the SWS strainers following a LOOP. The licensee initiated actions to update

current licensee procedures to include guidance to manually clean the strainers and

closed the associated condition report on May 10, 2011.

The inspectors reviewed NCR 463149 and the actions associated with its closure. The

SWS strainers are designed to strain debris from Lake Robinson and support the

operation of the SWS. The SWS strainers include a motor, wiper, timer and control

switches which are all powered via, MCC-7, a non-safety related source. The wipers

have a self-cleaning feature which will automatically start on a high differential pressure

signal across the strainers. The high differential pressure sensed across the strainers

would also actuate an alarm in the control room. The inspectors reviewed the

annunciator response procedure, AP-008, SW Strainer Hi DP, and questioned whether

the instrumentation required to alert the control room operators was powered from the

same non-safety related power source as the strainers. The licensee reviewed the

inspectors concern and determined that the control room alarm associated with the SW

strainers was also powered by MCC-7. The inspectors were concerned that an external

event, such as a tornado or hurricane, coincident with a LOOP, may challenge the

operation of the SWS, due to the lack of control room indication of a plugged strainer.

The inspectors concluded that, without indication, control room operators would be

unable to identify the need to take the appropriate actions to manually clean the strainer

prior to a significant loss of SWS flow. The licensee documented this issue in NCR

Enclosure

14

473900 and initiated actions to change plant procedures to include guidance to locally

monitor SWS parameters and manually clean the strainers following a LOOP.

Analysis: The failure to establish adequate procedural guidance to monitor SWS

parameters and manually operate the SWS strainers following a LOOP was a

performance deficiency. The finding was more than minor because if left uncorrected,

the performance deficiency has the potential to lead to a more significant safety concern.

Specifically, the failure to clean the service water strainers, following a LOOP, could

impact the operation of the service water system. A Significance Determination Process

(SDP) Phase 1 screening was performed and determined that this finding was within the

mitigating systems cornerstone and potentially risk significant due to a seismic, flooding

or severe weather initiating event. Consequently a Phase 3 analysis was required. Two

dominant core damage sequences were evaluated. The first dominant accident

sequence consisted of a reactor trip, initiated by a loss of condenser heat sink, and a

subsequent failure to initiate high pressure recirculation, which leads to a RCP seal loss

of coolant accident. The second dominant accident sequence consisted of a LOOP

followed by the failure of the turbine-driven AFW pump and non-recovery of the electrical

system. A senior reactor analyst determined that the lack of a procedure for a loss of

the service water strainers due to an external event (i.e., loss of offsite power removing

power to the strainers and causing debris to clog the system) was of very low risk

significance i.e., Green. The main contributors to the low risk results were: 1) the low

likelihood of a total loss of service water event, and 2) the probability of recovery of the

strainers and/or the system despite the lack of procedures.

The inspectors determined that the finding has a cross-cutting aspect in the Corrective

Action Program component of the Problem Identification and Resolution area, because

the licensee failed to thoroughly evaluate the issue such that the resolution addressed

the cause and extent of conditions, as necessary. Specifically, licensees evaluation of

the NCR associated with the lack of plant procedures to manually operate the SWS,

failed to recognize that the control room indication associated with a plugged SWS

strainer would be lost following a LOOP. (P.1(c))

Enforcement: TS 5.4.1, Administrative Control, Procedures, requires that written

procedures shall be established, implemented, and maintained, covering applicable

procedures recommended in Regulatory Guide 1.33, Appendix A, February 1978.

Section 3 of Regulatory Guide 1.33, Appendix A, February 1978 states that operation of

systems that affect the safety of the nuclear power plant, including the service water

system, should be conducted in accordance with written procedures. The licensee

established, OP-903, Service Water System, as the governing procedure for operation of

the Service Water System. Contrary to the above, on May 4, 2011, it was identified that

the licensees procedure, OP-903, failed to provide adequate guidance for the operation

of the SWS strainers following a LOOP. The licensee revised the plant procedure to

include guidance to locally monitor SWS parameters and manually clean the strainers

following a LOOP. Because this violation was of very low safety significance and it was

entered into the licensees corrective action program (AR 473900473900, this violation is being

treated as a non-cited violation (NCV), consistent with the NRC Enforcement Policy.

This violation is therefore designated as NCV 05000261/2011004-02, Failure to

Establish Guidance to Monitor and Operate Service Water Strainers Following LOOP.

Enclosure

15

1R18 Plant Modifications

.1 Permanent Modification

a. Inspection Scope

The inspectors reviewed the permanent modification described in Engineering Change 81014, C Charging Pump Oil Level Sightglass Installation, to verify that the modification

design, implementation, and testing did not degrade the design basis, and performance

capabilities of risk significant equipment and did not place the plant in an unsafe or

unanalyzed condition. The inspectors verified that the modification satisfied the

requirements of Procedure EGR-NGGC-005, Engineering Change, and 10 CFR 50,

Appendix B, Criterion III, Design Control. Documents reviewed are listed in the

Attachment.

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the seven post-maintenance tests (PMT) listed below, the inspectors witnessed the

test and/or reviewed the test data to verify that test results adequately demonstrated

restoration of the affected safety functions described in the UFSAR and TS. Documents

reviewed are listed in the Attachment.

The following tests were witnessed/reviewed:

• WO 1496981, Replace CVC-2080, C Charging Pump Suction Relief Valve, PMT in

accordance with PLP-111, Leak Reduction Program, Rev. 14

• WO 1659779, 230 kV Auxiliary Relay Inspection, PMT in accordance with WO 1659779

• WO 1528300, Replace GEMCO Switch on Auxiliary Feedwater Header Discharge to

Steam Generator C, PMT in accordance with OST-201-2, Motor Driven Auxiliary

Feedwater System Component Test-Train B, Rev. 29

• WO 1957584, Replacement of Control Rod Position Indicator P-10 Module, PMT in

accordance with WO 1957584

• WO 1739819, A Safety Injection Pump Bearing Cooler Cleaning, PMT in

accordance with OST-151-1, Safety Injection System Components Test - Pump A,

Rev. 34

• WO 1686830, Installation of Auto-Start Circuitry Per EC 69423, PMT in accordance

with SP-1540, Dedicated Shutdown Diesel Generator Auto Start Functional Test,

Rev. 3

Enclosure

16

• WO 1620791, SI Pump B Line and Thrust Bearing Oil Reservoir Repairs, PMT in

accordance with procedures OST-151-1, Comprehensive Flow Test for Safety

Injection Pump B, Rev. 17, and OST-155, Safety Injection System Integrity Test,

Rev. 32

The inspectors reviewed the following ARs associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 478651, V6-12A Failed to Stroke from RTGB during the Performance of PMT

• 479781, Inadequate PMT Following EC Installation

b. Findings

No findings were identified.

1R20 Refueling and Outage Activities

For the outage that began on September 26 and ended on September 30, the inspectors

evaluated licensee outage activities as described below to verify that the licensee

considered risk in developing outage schedules, adhered to administrative risk reduction

methodologies they developed to control plant configuration, and adhered to operating

license and technical specification requirements that maintained defense-in-depth. The

inspectors also verified that the licensee developed mitigation strategies for losses of the

following key safety functions:

• decay heat removal

• inventory control

• power availability

• reactivity control

• containment

Documents reviewed are listed in the Attachment.

.1 Review of Outage Plan

a. Inspection Scope

The inspectors reviewed the outage risk control plan to verify that the licensee had

performed adequate risk assessments, and had implemented appropriate risk-

management strategies when required by 10 CFR 50.65(a)(4).

b. Findings

No findings were identified.

Enclosure

17

.2 Licensee Control of Outage Activities

a. Inspection Scope

During the outage, the inspectors observed the items or activities described below to

verify that the licensee maintained defense-in-depth commensurate with the outage risk-

control plan for key safety functions and applicable technical specifications when taking

equipment out of service.

• Clearance Activities

• Electrical Power

• Decay Heat Removal (DHR)

• Reactivity Control

• Fatigue Management

The inspectors also reviewed responses to emergent work and unexpected conditions to

verify that resulting configuration changes were controlled in accordance with the outage

risk control plan, and to verify that control-room operators were kept cognizant of the

plant configuration.

b. Findings

No findings were identified.

.3 Monitoring of Heatup and Startup Activities

a. Inspection Scope

Prior to mode changes and on a sampling basis, the inspectors reviewed system lineups

and/or control board indications to verify that TSs, license conditions, and other

requirements, commitments, and administrative procedure prerequisites for mode

changes were met prior to changing modes or plant configurations. Also, the inspectors

periodically reviewed reactor coolant system (RCS) boundary leakage data, and

observed the setting of containment integrity to verify that the RCS and containment

boundaries were in place and had integrity when necessary. The inspectors reviewed

reactor physics testing results to verify that core operating limit parameters were

consistent with the design.

b. Findings

No findings were identified.

Enclosure

18

.4 Identification and Resolution of Problems

a. Inspection Scope

Periodically, the inspectors reviewed the items that had been entered into the CAP to

verify that the licensee had identified problems related to outage activities at an

appropriate threshold and had entered them into the corrective action program. For the

significant problems documented in the corrective action program and listed below, the

inspectors reviewed the results of the investigations to verify that the licensee had

determined the root cause and implemented appropriate corrective actions, as required

by 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.

• 413865, Inoperability of Pressurizer Heaters from B train EDG

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the eight surveillance tests listed below, the inspectors witnessed testing and/or

reviewed the test data to verify that the systems, structures, and components involved in

these tests satisfied the requirements described in the TS, the UFSAR, and applicable

licensee procedures, and that the tests demonstrated that the SSCs were capable of

performing their intended safety functions. Documents reviewed are listed in the

Attachment.

• OST-750-2, Control Room Emergency Ventilation System- Train B, Rev. 18

• OST-554, Turbine Bearing Oil System and E-H Control System Hydraulic

Components Test (Monthly), Rev. 20

• OST-413, Temporary Skid Diesel Generator, Rev. 8

• OST-551-1, Turbine Valve Test, Rev. 4

• SPP-038, Installation, Operation, and Removal of Supplemental Cooling for HVH-1,

2, 3, & 4, Rev. 11

Inservice Testing Surveillance

• OST-108-3, Comprehensive Flow Test For Boric Acid Pump A, Rev. 12

• Containment Isolation Valve Surveillance OST-014, LLRT of Personnel Air Lock

Door Seals (Within Three Days of Entry When CV Integrity is Required), Rev. 15

Enclosure

19

Reactor Coolant System Leakage Surveillance

• OST-051, Reactor Coolant Leakage Evaluation (Every 72 Hours During Steady State

Operation and Within 12 Hours of Reaching Steady State Operation) Rev. 44

The inspectors reviewed the following AR associated with this area to verify that the

licensee identified and implemented appropriate corrective actions:

• 474876, Increase in Unidentified Reactor Coolant System Leakage

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

On July 26, 2011, the inspectors observed an emergency preparedness drill to verify

licensee self-assessment of classification, notification, and protective action

recommendation development in accordance with 10 CFR 50, Appendix E. The

inspectors also reviewed the Post-Drill Critique Roll-Up and Review Checklist to verify

that the licensee properly identified failures in classification, notification and protective

action recommendation development activities.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors verified the PIs identified below. For each PI, the inspectors verified the

accuracy of the PI data that had been previously reported to the NRC by comparing

those data to the actual data, as described below. The inspectors also compared the

licensees basis in reporting each data element to the PI definitions and guidance

contained in NEI 99-02, Regulatory Assessment Indicator Guideline. In addition, the

inspectors interviewed licensee personnel associated with collecting, evaluating, and

distributing these data.

Enclosure

20

Initiating Events Cornerstone

• Unplanned Scrams per 7000 critical hours

• Unplanned Scrams with Complications

• Unplanned Power Changes per 7000 critical hours

For the period from the first quarter of 2010 through the fourth quarter of 2010, the

inspectors reviewed a selection of licensee event reports, operator log entries, daily

reports (including the daily CR descriptions), monthly operating reports, and PI data

sheets to verify that the licensee had accurately identified the number of scrams and

unplanned power changes greater than 20 percent that occurred during the subject

period. The inspectors compared those numbers to the numbers reported by the

licensee for the PI. The inspectors also reviewed the accuracy of the number of critical

hours reported, and the licensees basis for crediting normal heat removal capability for

each of the reported reactor scrams.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of ARs

a. Inspection Scope

To aid in the identification of repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed frequent screenings of items entered into

the CAP. The review was accomplished by reviewing daily AR reports.

b. Findings

No findings were identified.

.2 Annual Sample Review

a. Inspection Scope

The inspectors selected AR 463241463241 Response to AR 422989422989 Decline in Corrective

Action Program (CAP) Performance noted similarities with the Davis Besse CAP decline

lessons learned for detailed review. The inspectors reviewed this report to verify:

• complete and accurate identification of the problem in a timely manner;

• evaluation and disposition of performance issues;

• evaluation and disposition of operability and reportability issues;

• consideration of extent of condition, generic implications, common cause, and

previous occurrences;

Enclosure

21

• appropriate classification and prioritization of the problem;

• identification of root and contributing causes of the problem;

• identification of corrective actions which were appropriately focused to correct the

problem; and

• completion of corrective actions in a timely manner.

b. Observations and Findings

No findings were identified. The inspectors noted that licensees review of the corrective

actions implemented as a result of the Davis Besse reactor vessel head degradation

was thorough and comprehensive. The licensee determined that some corrective

actions involving ongoing periodic reviews of the event with staff had lost the clear

linkage of the Davis Besse event with the purpose of the reviews. The licensee added

additional guidance to directly link the Davis Besse event to the review session.

.3 In-Depth Review of Operator Workarounds

a. Inspection Scope

The inspectors performed a detailed review of the Operator Workarounds and Operator

Burdens List as of July 28, 2011, to verify the full extent of the issues were identified, an

appropriate evaluation was performed, and appropriate corrective actions were specified

and prioritized. The inspectors reviewed and walked down selected Caution Tags to

assess the impact to the operators. The inspectors met with Operations management to

discuss the current status of the Operator Workaround and Operator Burdens list.

b. Findings

No findings were identified.

4OA3 Event Follow-up

.1 (Closed) LER 2011-001-00, Condition Prohibited by Technical Specifications When

Non-Seismic System was Aligned to Refueling Water Storage Tank due to Regulatory

Requirements not Adequately Incorporated in Plant Documentation.

On May 4, 2011, the licensee determined that over the last 40 years, the plant

periodically performed cleanup of the Refueling Water Storage Tank (RWST) by aligning

the non-seismically qualified refueling water purification system to the safety-related and

seismically qualified RWST without recognizing that the action rendered the RWST

inoperable. As a result, on multiple occasions the RWST was inoperable for a period

longer than allowed by Technical Specifications. The cause of this event was that

regulatory requirements for the separation of seismically qualified and non-seismically

qualified SSCs were not adequately incorporated into the Design Basis Document and

the UFSAR. The inspectors reviewed the corrective actions and determined that they

were adequate. The enforcement aspects of this LER were documented in IR 05000261/2011003, Section 1R15, as a Green NCV 05000261/2011003-03. The LER

Enclosure

22

was reviewed and no additional findings were identified and no additional violations of

NRC requirements occurred. This LER is closed.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors observed Security force personnel and

activities to ensure that the activities were consistent with licensee security procedures

and regulatory requirements relating to nuclear plant security. These observations took

place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities

did not constitute any additional inspection samples. Rather, they were considered an

integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings were indentified.

.2 Operation of an Independent Spent Fuel Storage Installation (ISFSI)

a. Inspection Scope

The inspectors performed a walkdown of the two ISFSIs on site (reference dockets 72-3

and 72-60) and monitored the activities associated with the dry fuel storage campaign

conducted July 11 through July 15. The inspectors also reviewed changes made to

programs and procedures and their associated 10 CFR 72.48 screens and/or

evaluations to verify that changes made were consistent with the license or Certificate of

Compliance; reviewed records to verify that the licensee has recorded and maintained

the location of each fuel assembly placed in the ISFSIs; and reviewed surveillance

records to verify that daily surveillance requirements were performed as required by

technical specifications. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On November 14, 2011, the resident inspectors presented the inspection results to Mr.

Thomas Cosgrove and other members of his staff. The inspectors confirmed that

proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Buzard, Licensing

T. Cosgrove, Plant General Manager

H. Curry, Training Manager

S. Garrity, Environmental & Chemistry Superintendent

W. Gideon, Vice President

K. Drown, Nuclear Assurance Manager

B. Houston, Radiation Protection Superintendent

C. Kamilaris, Manager, Support Services - Nuclear

G. Kilpatrick, Operations Manager

L. Martin, Engineering Manager

B. Matherne, Outage & Scheduling Manager

C. Morris, Maintenance Manager

NRC personnel

R. Musser, Chief, Reactor Projects Branch 4

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000261/2011004-01 AV Water Intrusion into Safety-Related Buildings due to

Inadequate Design of Site Storm Water Runoff

Drainage System (Section 1R01)

Closed

05000261/2011003-01 URI Rainstorm Results in Flooding of the Power Block

(Section 1R01)

05000261/2011-001-00 LER Condition Prohibited by Technical Specifications

When Non-Seismic System was Aligned to Refueling

Water Storage Tank due to Regulatory Requirements

not Adequately Incorporated in Plant Documentation

(Section 4OA3)

Opened & Closed

05000261/2011004-02 NCV Failure to Take Prompt Corrective Actions to

Establish Guidance to Monitor and Operate Service

Water Strainers Following LOOP (Section 1R15)

Discussed

None

Attachment

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Other documents

Calculation RNP-F/PSA-0009 Rev. 1, Assessment of Internally Initiated Flood Events

UFSAR Section 3.4, Water Level (Flood) Design

IPEEE Section 5.4, External Floods

Root Cause Evaluation Report for NCR 468235

Section 1R04: Equipment Alignment

Partial System Walkdown

Procedures

OP-402, Auxiliary Feedwater System, Rev 77

OP-905, Instrument and Air Station System Checklist, Rev. 107, Attachment 10.1

OP-202, Safety Injection and Containment Vessel Spray System, Rev. 86, Attachment 10.1

Other documents

HUN-NGGC-0001, Clearance Information Tags (CIT) Hung on Wrong Components, Rev. 8

Drawing 5379-1082, Safety Injection System Flow Diagram, Rev. 44, Sheets 1-5

G-190200, Instrument & Station Air System Flow Diagram, Rev.34, Sheets 1-10

Section 1R05: Fire Protection

UFSAR Sections of Appendix 9.5.1A

Section 3.7.1 Fire Zone 25A-Turbine Building East Ground Floor

Section 3.7.2 Fire Zone 25B-Turbine Building West Ground Floor

Section 3.7.5 Fire Zone 25E-Turbine Building East Mezzanine

Section 3.7.6 Fire Zone 25F-Turbine Building West Mezzanine

Section 3.1.9 Fire Zone 3-Safety Injection Pump Room

Section 3.3 Component Cooling Pump Room

Section 3.1.5.2 Battery Room

Procedures

FP-001, Fire Emergency, Rev. 59

FP-003, Control of Transient Combustibles, Rev. 26

FP-004, Duties of a Fire Watch, Rev. 14

FP-012, Fire Protection Systems Minimum Equipment and Compensatory Actions, Rev. 13

OMM-002, Fire Protection Manual, Rev. 43

OMM-003, Fire Protection Pre-Plans/Unit 2, Rev. 56

Drawings

HBR2 11937 Sheet 46 Fire Pre-Plan Turbine Building Ground Level

HBR2 11937 Sheet 48 Fire Pre-Plan A&B Aux. Boilers and Associated Fuel Oil Pumps

HBR2 11937 Sheet 58 Fire Pre-Plan Turbine Building Mezzanine Level

HBR2 11937 Sheet 19 Fire Pre-Plan Safety Injection Pump Room

Attachment

4

HBR2 11937 Sheet 8 Fire Pre-Plan Component Cooling Pump Room

HBR2 11937 Sheet 25 Fire Pre-Plan A and B Battery Room

Other documents

Fire Drill Scenario 02, Condensate Polishing Building, Rev. 1

Section 1R06: Flood Protection Measures

Procedures

AOP-014 Rev. 30, Component Cooling Water System Malfunction

AOP-022 Rev. 35, Loss of Service Water

AOP-032, Rev. 7, Response to Flooding from the Fire Protection System

Other documents

Calculation RNP-F/PSA-0009 Rev. 1, Assessment of Internally Initiated Flood Events

UFSAR Section 3.4, Water Level (Flood) Design

Section 1R11: Licensed Operator Requalification

Other documents

Exercise Guide LOCT 03-4

Section 1R12: Maintenance Effectiveness

Procedures

MST-932, Low Autostop Oil Pressure and Turbine Stop Valve Closure Testing, Rev. 4

MST-551, Turbine Trip Logic Channel Testing, Rev. 30

OST-551-1, Turbine Valve Test, Rev. 4

OST-101-3, CVCS Component Test Charging Pump C, Rev. 44

Work Orders

1932900, Investigate Source of Reduced C Charging Pump Flow

1849467, Perform Turbine Valve Testing

1959363, Investigate No Turbine Stop Valve Indication

1938034, Repair CVC-277B, B Charging Pump Recirculation Valve Seat Leakage

1635854, Clean and Inspect the DSDG

Action Requests

466923, C Charging Pump Lower than Expected Flow.

478069 Right Turbine Stop Valve Did Not Go Completely Closed During Testing

467439, Recurring DSDG Fuel Pressure and Generator Frequency Outside the Surveillance

Acceptance Criteria

461540, DSDG Cooling Fans Require Blade Guards

460706, A DSDG Ventilation Fan Does Not Start

458851, Wiring Insulation is Nicked

402003, DSDG Operator Logs Revised Prior to Engineering Change Implementation

396769, DSDG Output Breaker Indicating Light is Out

Attachment

5

Other documents

Scoping and Performance Criteria for the Dedicated Shutdown Diesel System

Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation

Procedures

OMM-048, Work Coordination and Risk Assessment, Rev. 48

Work Orders

01686830, DSD-GEN Install/Term New Auto Start Components

Action Requests

474424, A Charging Pump Stuffing Box Temp Exceeds Break In Limit

474425, B Charging Pump Speed Controller Failed to Maximum

474549, PIC-402 Guidance Does Not Match Technical Manual

474559, OMM-48, Add Information Concerning Protected Equipment

Other documents

Operating Logs

Risk Profile for July 4 through July 11

Section 1R15: Operability Evaluations

Procedures

AOP-22, Loss of Service Water, Rev.34

PLP-026, Corrective Action Program, Rev. 5

APP-008-F7, South SW HDR LO PRESS, Rev.55

APP-008-F5, SW STRAINER A/B HI P

Action Requests

474425, B Charging Pump Speed Control Failed High

485071, A train SI accumulator leaking

463149, Manual Operation of the Service Water Header Strainers

473900, Monitoring of SW Strainer DP After Loop

Other documents

Quick Cause Evaluation Report for NCR 485071

Service Water Generic Letter 89-13 Item IV-Single Failure Analysis, 1/23/91

CPR 11000005, Service Water System Design Bases Validation Report

OPS-NGGC-1305, Service Water Leak at SWS-56, Rev. 5

Section 1R18: Plant Modifications

Other documents

EC 81014, C Charging Pump Oil Level Sightglass Installation

EC 79219, Oil Level Sight Gage on Charging Pumps

Attachment

6

Section 1R19: Post Maintenance Testing

Procedures

OST-201-2, MDAFW System Component Test- Train B, Rev. 29

SP-1540, Dedicated Shutdown Diesel Generator Auto Start Functional Test, Rev. 3

PLP-033, Post-Maintenance Testing (PMT) Program, Rev. 54

OST-151-1, Comprehensive Flow Test for Safety Injection Pump B, Rev. 17

OST-155, Safety Injection System Integrity Test, Rev. 32

OST-910, Dedicated Shutdown Diesel Generator (Monthly), Rev. 48

Work Orders

WO 1528301-01, Replace CS/AFW-V2-20A GEMCO Control Switch

WO 1528300-01, Replace GEMCO Switch CS/AFW-V2-16C

WO 1620791, SI Pump B Line and Thrust Bearing Oil Reservoir Repairs

Action Requests

476370, B MDAFW Pump Scheduled Unavailability Time Exceeded

476065, Incorrect Gasket Fit for MDAFW Pump Lube Oil CLR

Other documents

EC 69423, Installation of Auto Start Equipment for DS Diesel Generator, Rev. 8

Section 1R20: Refueling and Outage Activities

Action Requests

490132, Pressurizer Backup Group B Heaters Failed to Energize

490143, Upper Trip Contact Closed on UAT PH-B Differential Relay

490180, FCV-488 Excessive Leak-by on Rx Trip

490184, B Main Feedwater Pump Tripped on Plant Trip

490403, Unable to Completely Isolate Steam Flow to Main Turbine

490524, Rod L-5 Rod Bottom Light Cleared while Rod was Inserted

Other documents

EC 82964, Temporarily Disable Fire Detection Zone 26A Train Detection

Section 1R22: Surveillance Testing

Procedures

OST-750-2, Control Room Emergency Ventilation Train B, Rev. 18

OST-554, Turbine Bearing Oil System and E-H Control System Hydraulic Components Test

(Monthly), Rev. 20

OST-413, Temporary Skid Diesel Generator, Rev. 8

OST-551-1, Turbine Valve Test, Rev. 4

SPP-038, Installation, Operation, and Removal of Supplemental Cooling for HVH-1, 2, 3, & 4,

Rev. 11

Other documents

SD-036, System Description: HVAC System, Rev. 13

UFSAR Section 9.4, Air Conditioning, Heating, Cooling, and Ventilation System, Rev. 22

Attachment

7

Section 1EP6: Drill Evaluation

Other documents

Emergency Response Organization Exercise Scenario Package for 07-26-2011

Emergency Notification Forms for the 07-26-2011 Exercise

Section 4OA1: Performance Indicator Verification

Other documents

Operator logs

Section 4OA2: Identification and Resolution of Problems

Procedures

CAP-NGGC-0200, Corrective Action Program, Rev. 34

CAP-NGGC-0206, Corrective Action Program Trending and Analysis, Rev. 5

Action Requests

463241, Davis Besse Lessons Learned Corrective Action Review

422989, Robinson CAP Performance Decline

Section 4OA5 Other Activities

Procedures

ISFS-012, 24P-ISFSI Transfer Cask Handling Operations for Fuel Loading, Rev.12

AOP-028, [Independent Spent Fuel Storage Installation] Abnormal Events, Rev. 8

Action Requests

476365, Trouble Disengaging OS-197 RAM Grapple

Other documents

RNP-24PTH-L-1C-HZ11, Fuel Selection Approval Sheet, 2011

RNP-24PTH-L-1C-HZ12, Fuel Selection Approval Sheet, 2011

RNP-24PTH-L-1C-HZ09, Fuel Selection Approval Sheet, 2011

RNP-24PTH-L-1C-HZ14, Fuel Selection Approval Sheet, 2011

RNP-24PTH-L-1C-HZ13, Fuel Selection Approval Sheet, 2011

Attachment