IR 05000346/2013005

IR 05000346-13-005; 10/1/13 - 12/31/13; Davis-Besse Nuclear Power Station; Licensed Operator Requalification Program; Maintenance Risk Assessments and Emergent Work Control; Radiological Hazard Assessment and Exposure Controls

ML14030A376
Person / Time
Site:	Davis Besse
Issue date:	01/30/2014
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Lieb R FirstEnergy Nuclear Operating Co
References
IR-13-005
Download: ML14030A376 (56)

Text

January 30, 2014

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION NRC INTEGRATED INSPECTION REPORT 050000346/2013005

Dear Mr. Lieb:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on January 14, 2014, with yourself and other members of your staff.

Based on the results of this inspection, two NRC-identified findings and one self-revealed finding of very low safety significance were identified. Each of the findings also involved a violation of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating the issues 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 any NCV, 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 Inspectors' Office at the Davis-Besse Nuclear Power Station. 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 Inspectors at the Davis-Besse Nuclear Power Station.

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

Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects Docket No. 50-346 License No. NPF-3

Enclosure:

Inspection Report 05000346/2013005 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-346 License No: NPF-3 Report No: 05000346/2013005 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: October 1, 2013, through December 31, 2013 Inspectors: D. Kimble, Senior Resident Inspector T. Briley, Resident Inspector M. Bielby, Senior Operations Licensing Examiner J. Laughlin, Emergency Preparedness Inspector M. Marshfield, Senior Resident Inspector - Perry Station M. Mitchell, Radiation Protection Inspector C. Moore, Operations Licensing Examiner J. Neurauter, Senior Engineering Inspector Approved by: J. Cameron, Chief Branch 4 Division of Reactor Project Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000346/2013005; 10/1/13-12/31/13; Davis-Besse Nuclear Power

Station; Licensed Operator Requalification Program; Maintenance Risk Assessments and Emergent Work Control; Radiological Hazard Assessment and Exposure Controls.

This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Three Green findings were identified by the inspectors. All three of the findings were considered non-cited violations (NCVs) of NRC regulations. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the Cross Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

A self-revealed finding of very low safety significance and associated NCV of Technical Specification (TS) 5.4.1(a) were identified when the licensee failed to properly implement plant procedures for placing component cooling water (CCW) Pump 2 in standby status. Specifically, the licensee did not set the CCW Heat Exchanger 2 Outlet Temperature Indicating Controller, TIC1434, to the proper set point. As a result, Service Water (SW) Train 2 header pressure significantly dropped, an automatic isolation of SW cooling to the Turbine Plant Cooling Water (TPCW) heat exchangers occurred with realignment to circulating water cooling to the heat exchangers, and the licensee entered the Loss of SW Abnormal Operating procedure.

This finding was determined to be of more than minor significance because it directly impacted the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Using Exhibit 1, which contains the screening questions for the Initiating Events Cornerstone of reactor safety, the inspectors determined that the finding screened as very low safety significance, because it did not adversely impact any accident, transient, support system loss, steam generator tube rupture, or external event initiators. This finding has a cross-cutting aspect in the area of human performance, work practices component, because the licensee failed to communicate human error prevention techniques, such as holding pre-job briefings and self and peer checking to ensure work was performed safely and personnel do not proceed in the face of uncertainty or unexpected circumstances.

(H.4(a)) (Section 1R11.3)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR 50.65(a)(4) for the licensees failure to implement appropriate risk management actions during planned maintenance for Emergency Diesel Generator (EDG) No. 2. Specifically, field observations of the maintenance activities by the inspectors called into question the availability of EDG No. 2, which the licensee was crediting as "available" for at-power risk management purposes during the maintenance.

Afterwards, it was identified that certain aspects of the planned maintenance activities should have resulted in the EDG being declared "unavailable" for a period of about an hour, and during this period the station should have entered a heightened awareness condition (yellow) for at-power risk management.

The finding was determined to be of more than minor significance because it was associated with the Mitigating Systems Cornerstone of Reactor Safety and directly impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, as a result of the licensee's error, EDG No. 2 was rendered unavailable without the station entering the appropriate heightened awareness condition (yellow) for at-power risk management. The inspectors evaluated the finding using IMC 0609,

Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. Using Flowchart 1 - Assessment of Risk Deficit, the inspectors determined the finding to be of very low safety significance (Green) because the difference in incremental core damage probability (ICDP), or "risk deficit," at the station during the one-hour period when EDG No. 2 should have been unavailable and the station in a heightened awareness condition (yellow) for at-power risk management was much less than the threshold value of 1.0E-6 specified in Appendix K. This finding has a cross-cutting aspect in the area of human performance, work control component, because the licensee had failed to appropriately plan the EDG No. 2 work activities by incorporating applicable risk insights. (H.3(a)) (Section 1R13.1)

Cornerstone: Public Radiation Safety

Green.

The inspectors identified a finding of very low safety significance and an associated NCV of TS 5.4.1. Specifically, the licensee failed to maintain procedures to ensure compliance with TS 5.5.3, Radioactive Effluent Controls Program." Corrective actions were developed in the Corrective Action Program (CAP) and implemented.

The inspectors determined the finding was more than minor because it associated with the Public Radiation Safety Cornerstone and impacted cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding was assessed using IMC 0609, Attachment D, for the Public Radiation Safety Significance Determination Process (SDP) and determined to be of very low safety significance because it involved the Effluent Release Program but did not involve a failure to implement the program and did not involve a public dose greater than 10 CFR Part 50 Appendix I Criterion or 10 CFR 20.1301(e).

The inspectors also determined that no cross-cutting aspect applied to the performance deficiency, therefore no cross-cutting aspect was assigned. (Section 2RS6.1)

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

The unit began the inspection period operating at full power and, with the exception of several small power maneuvers (e.g., reductions of 10 percent power or less) to facilitate planned evolutions and testing, remained operating at or near full power for the entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

The inspectors conducted a review of the licensees preparations for winter conditions to verify that the plants design features and implementation of procedures were sufficient to protect mitigating systems from the effects of adverse weather. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Cold weather protection, such as heat tracing and area heaters, was verified to be in operation where applicable. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report. The inspectors reviews focused specifically on the following plant systems due to their risk significance or susceptibility to cold weather issues:

• Service Water (SW) system; and

• Borated Water Storage Tank and associated piping.

This inspection constituted one winter seasonal readiness preparations sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• Emergency Diesel Generator (EDG) No. 2 when EDG No. 1 was out-of-service for planned surveillance testing during the week ending October 26, 2013;

• EDG No. 1 when EDG No. 2 was unavailable for a planned maintenance work window during the week ending November 2, 2013;

• High Pressure Injection (HPI) Train 1 when HPI Train 2 was out-of-service for planned surveillance testing during the week ending November 9, 2013; and

• Auxiliary Feedwater (AFW) Train 1 when AFW Train 2 was out-of-service for a planned maintenance work window during the week ending December 7, 2013.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization.

Documents reviewed are listed in the Attachment to this report.

These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Protection Zone Inspections

a. Inspection Scope

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

• Electrical Penetration Room No. 1 (Auxiliary Building, Room 402);

• Mechanical Penetration Room No. 2 (Auxiliary Building, Room 236);

• Mechanical Penetration Room No. 4 (Auxiliary Building, Room 314);

• EDG Room No. 1 (Diesel Generator Building, Room 318);

• EDG Room No. 2 (Diesel Generator Building, Rooms 319 and 319A); and

• Auxiliary Building and Turbine Building Risk-Significant Fire Doors.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events (IPEEE) with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.

These activities constituted six quarterly fire protection zone inspection tour samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Biennial Written and Annual Operating Test Results

a. Inspection Scope

The inspectors reviewed the overall pass/fail results of the Annual Operating Test, administered by the licensee from October 21 - December 9, 2013, as required by 10 CFR 55.59(a). The results were compared to the thresholds established in IMC 0609, Appendix I, Licensed Operator Requalification Significance Determination Process," to assess the overall adequacy of the licensees Licensed Operator Requalification Training Program to meet the requirements of 10 CFR 55.59.

This inspection constituted a single annual licensed operator requalification examination results sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Review of Licensed Operator Simulator Training

a. Inspection Scope

On November 13, 2013, the inspectors observed a crew of licensed operators in the plants simulator during a graded simulator scenario. The graded scenario observed was part of the licensee's Annual Operating Test, as required by 10 CFR 55.59(a). The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. In addition, the inspectors verified that the licensees personnel were observing NRC examination security protocols to ensure that the integrity of the graded scenario was being protected from being compromised. The inspectors evaluated the following areas:

• Licensed operator performance;

• The clarity and formality of communications;

• The ability of the crew to take timely and conservative actions;

• The crews prioritization, interpretation, and verification of annunciator alarms;

• The correct use and implementation of abnormal and emergency procedures by the crew;

• Control board manipulations;

• The oversight and direction provided by licensed Senior Reactor Operators (SROs); and

• The ability of the crew to identify and implement appropriate TS actions and Emergency Plan (EP) actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

These observations and activities by the inspectors constituted a single quarterly licensed operator requalification program simulator training inspection sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.3 Resident Inspector Quarterly Observation of Control Room Activities

a. Inspection Scope

During the course of the inspection period, the inspectors performed numerous observations of licensed operator performance in the plants control room to verify that operator performance was adequate and that plant evolutions were being conducted in accordance with approved plant procedures. Specific activities observed that involved a heightened tempo of activities or periods of elevated risk included, but were not limited to:

• Plant power maneuvering and reactivity manipulations in support of Reactor Trip Breaker 'B' periodic testing during the week ending October 19, 2013;

• Plant power maneuvering and reactivity manipulations in support of control rod exercise testing, main turbine valve testing, and condensate pump maintenance during the week ending October 26, 2013;

• Plant power maneuvering and reactivity manipulations in support of AFW pump periodic testing during the week ending October 26, 2013;

• Operator and licensee technical staff response to a low bearing oil alarm on Reactor Coolant Pump (RCP) 2-1, and subsequent emergent at-power containment entry to add oil to the pump during the week ending October 26, 2013; and

• Electric plant switching and alignment operations to support 4160 Vac circuit breaker racking and replacement maintenance activities during the week ending November 9, 2013.

The inspectors evaluated the following areas during the course of the control room observations:

• Licensed operator performance;

• The clarity and formality of communications;

• The ability of the crew to take timely and conservative actions;

• The crews prioritization, interpretation, and verification of annunciator alarms;

• The correct use and implementation of normal operating, annunciator alarm response, and abnormal operating procedures by the crew;

• Control board manipulations;

• The oversight and direction provided by on-watch SROs and plant management personnel; and

• The ability of the crew to identify and implement appropriate TS actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

These observation activities by the inspectors of operator performance in the stations control room constituted a single quarterly inspection sample as defined in IP 71111.11-05.

b. Findings

Operator Failure to Follow Procedure Results in Service Water System Transient Introduction A self-revealed finding of very low safety significance (Green) and associated NCV of TS 5.4.1(a) were identified when the licensee failed to properly implement plant procedures for placing component cooling water (CCW) Pump 2 in standby status.

Specifically, the licensee did not set the CCW Heat Exchanger 2 Outlet Temperature Indicating Controller, TIC1434, to the proper set point. As a result, SW Train 2 header pressure significantly dropped resulting in an automatic isolation of SW cooling to the Turbine Plant Cooling Water (TPCW) heat exchangers and subsequent automatic realignment of circulating water cooling to the TPCW heat exchangers. The licensee entered the Loss of SW Abnormal Operating procedure.

Description On October 30, 2013, the licensee was making preparations on nightshift to stop CCW Pump 2 and place the pump in standby status following EDG 2 testing performed on dayshift. The evolution involved stopping the pump and setting temperature indicating controller (TIC)1434 to a value (normally 110°F) that will maintain the CCW Heat Exchanger 2 Outlet Temperature Control Valve, SW 1434, closed to prevent excessive and unnecessary SW flow and potential low service water pressure. Low service water pressure initiates automatic isolation of non-safety service water loads and realigns those loads to the circulating water system.

At approximately 7:15 p.m., the command Senior Reactor Operator (SRO) directed the At-the-Controls Reactor Operator (ATC RO) to stop CCW Pump 2. The ATC RO performed a job-preview of CCW System Procedure (DB-OP-06262, Section 3.10) for stopping and placing CCW Pump 2 in standby. The CCW System Procedure included Note 3.10.3.c which indicated TIC1434 should normally be set to 110°F and a procedure step (3.10.3.c) which states the set point for TIC1434 should be set as directed by the Shift Manager.

At approximately 7:24 p.m., the ATC RO stopped CCW Pump 2 and then directed an equipment operator to adjust TIC1434 set point to 85 °F. The equipment operator performed the set point adjustment as directed by the ATC RO. At 7:28 p.m., SW 1434 throttled open as designed, since CCW temperature was approximately 95°F, and SW secondary header pressure dropped from approximately 79 psig to 50 psig. The control room received an alarm for SW Pump 2 Strainer Discharge Pressure Low at 7:32 p.m.

TPCW Heat Exchanger Inlet Header Isolation, SW 1395, stroked closed as expected to isolate SW to the TPCW heat exchangers and initiated realignment of circulating water cooling to the TPCW heat exchangers; the licensee entered the Loss of SW Abnormal Operating procedure, DB-OP-02511. SW Loop 2 secondary cooling was restored by closing SW 1395 approximately 3 minutes later. The plant was stabilized, and the abnormal operating procedure was exited at 8:25 p.m.

The ATC RO had the incorrect mindset that 85°F, the set point for the operating CCW train, was the correct temperature indicating controller set point for placing CCW Pump 2 in standby. No formal pre-job brief was held prior to the evolution and no communication took place with the shift manager, command SRO, or the equipment operator to verify the proper temperature indicating controller set point. The equipment operator was under the direction of the ATC RO, therefore did not have a procedure in-hand and did not question the incorrect set point.

Analysis The inspectors reviewed this finding using the guidance contained in Appendix B, Issue Screening, of IMC 0612, Power Reactor Inspection Reports. The inspectors determined that the licensees failure to properly implement procedures for placing CCW Pump 2 in standby was a performance deficiency that was reasonably within the licensees ability to foresee and correct and should have been prevented. This finding was associated with the Initiating Events Cornerstone of reactor safety and was of more than minor significance because it directly impacted the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Using Exhibit 1, which contains the screening questions for the Initiating Events Cornerstone of reactor safety, the inspectors determined that the finding screened as very low safety significance (Green) because it did not adversely impact any of the following parameters:

• Loss-of-Coolant Accident Initiators;

• Transient Initiators;

• Support System Loss Initiators;

• Steam Generator Tube Rupture Initiators; and

• External Event Initiators.

This finding has a cross-cutting aspect in the area of human performance, work practices component, because the licensee failed to communicate human error prevention techniques, such as holding pre-job briefings and self and peer checking to ensure work was performed safely and personnel do not proceed in the face of uncertainty or unexpected circumstances. (H.4(a))

Enforcement TS 5.4.1(a) requires the licensee to establish, implement, and maintain applicable written procedures for the safety-related systems and activities recommended in RG 1.33, Revision 2, Appendix A. Section 3(e) and 3(m) of RG 1.33, Revision 2, Appendix A, requires procedures for the proper operation of the plant at power, which would include any and all operations involving the CCW and SW systems. Contrary to this requirement, the licensee failed to properly implement written procedures for the operation of the CCW and SW systems resulting in a SW transient. Specifically, the licensee failed to properly perform Step 3.10.3.c of DB-OP-06262 to set CCW Heat Exchanger 2 Outlet Temperature Indicating Controller (TIC1434) to the proper set point to place CCW Pump in standby.

Because this finding was of very low safety significance, had been entered into the licensees CAP, and the licensee had taken or planned corrective actions under CR 2013-17521, the associated violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. Corrective actions taken by the licensee included communication of the issue to all operators and reinforcement of teamwork expectations. (NCV 05000346/2013005-01, Operator Failure to Follow Procedure Results in Service Water System Transient )

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

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

• Pressurizer and other selected American Society of Mechanical Engineering (ASME) Code safety valves;

• Fire Protection Systems and features; and

• The Maintenance Condition Monitoring Program for the Containment Shield Building.

The inspectors reviewed events such as where ineffective equipment maintenance could result in or had resulted in valid or invalid automatic actuations or system transients and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices;

• Identifying and addressing common cause failures;

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

• Characterizing system reliability issues for performance;

• Charging unavailability for performance;

• Trending key parameters for condition monitoring;

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

• Verifying appropriate performance criteria for systems, structures, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

The inspectors reviews constituted three quarterly maintenance effectiveness inspection samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

• Emergent work and containment entry associated with a low bearing oil level condition on RCP 2-1 during the week ending October 26, 2013;

• Planned work associated with receipt, rigging, and heavy load transport of two new steam generators to the site during the week ending October 26, 2013; and

• Planned and scheduled maintenance on the station's No. 2 EDG and its associated ventilation systems during the week ending December 7, 2013.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the Attachment to this report.

These maintenance risk assessments and emergent work control activities constituted three inspection samples as defined in IP 71111.13-05.

b. Findings

Emergency Diesel Generator No. 2 Rendered Unavailable By Scheduled Maintenance Introduction A finding of very low safety significance (Green) and an associated NCV of 10 CFR 50.65(a)(4), were identified by the inspectors for the licensee's failure to implement appropriate risk management actions during planned maintenance for EDG No. 2. Specifically, field observations of the maintenance activities by the inspectors called into question the availability of EDG No. 2, which the licensee was crediting as "available" for at-power risk management purposes during the maintenance.

Afterwards, it was identified that certain aspects of the planned maintenance activities should have resulted in the EDG being declared "unavailable" for a period of about an hour, and during this period the station should have entered a heightened awareness condition (yellow) for at-power risk management.

Description On December 2, 2013, the licensee scheduled several planned preventative maintenance activities for performance on EDG No. 2. Per the licensee's assessment of the scheduled work, EDG No. 2 was rendered inoperable for TS purposes, but remained available under the licensee's at-power risk management program and was considered completely capable of responding to a start signal demand if called upon.

Inspectors reviewing the licensee's planned maintenance activities and the actual work being performed in the No. 2 EDG room raised several questions regarding the EDG availability with the on-watch Operations shift crew. Subsequently, the Operations personnel consulted with licensee Engineering personnel and concluded that one of the planned maintenance activities, a preventative maintenance WO to check the calibration of the EDG No. 2 room temperature controller, had disabled that controller's function. In the event of a diesel start signal, none of the EDG No. 2 ventilation dampers would have repositioned to permit fresh air to enter the room. The licensee concluded that without any fresh air entering the room, the ability of EDG No. 2 to be able to perform its function could not be maintained, and the diesel should have been declared unavailable during the course of the temperature controller maintenance activity.

Later, the licensee determined that the period of EDG No. 2 unavailability should have been approximately one hour. Additionally, licensee Operations personnel also concluded that during this period with EDG No. 2 unavailable that the station should have entered a heightened awareness condition (yellow) for at-power risk management.

Analysis The inspectors determined that the licensee's failure to accurately assess the availability of the No. 2 EDG and appropriately implement the risk management actions associated with the scheduled EDG maintenance activities constituted a performance deficiency that was reasonably within the licensee's ability to foresee and correct, and which should have been prevented. This finding was associated with the Mitigating Systems Cornerstone of Reactor Safety and was determined to be of more than minor significance because it was associated with cornerstone attribute of equipment performance 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)."

The inspectors evaluated the finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. Using Flowchart 1 - Assessment of Risk Deficit, the inspectors determined the finding to be of very low safety significance (Green) because the difference in Incremental Core Damage Probability (ICDP), or "risk deficit," at the station during the one-hour period when EDG No. 2 should have been unavailable and the station in a heightened awareness condition (yellow) for at-power risk management was much less than the threshold value of 1x10-6 specified in Appendix K.

Using IMC 0310, "Components Within the Cross-Cutting Areas," the inspectors determined that the finding had a cross-cutting aspect in the area of human performance, work control component, because the licensee had failed to appropriately plan the EDG No. 2 work activities by incorporating applicable risk insights. It was later identified that this particular room temperature controller calibration check had typically been performed as part of a larger scope EDG outage window when the diesel would have already been unavailable for risk management purposes. (H.3(a))

Enforcement The requirements of 10 CFR 50.65(a)(4) state, in part, that before performing maintenance activities (including but not limited to surveillance, post-maintenance testing (PMT), and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to these requirements, on the morning of December 2, 2013, for a period of approximately one hour the licensee had failed to adequately assess and manage the risk associated with a scheduled maintenance activity for the EDG No. 2 room temperature controller. Unbeknownst to the licensee, this maintenance activity inadvertently rendered the No. 2 EDG unavailable for station risk management purposes, which should have resulted in the licensee placing the station in a heightened awareness condition (yellow) for at-power risk management.

The licensee entered this issue into their CAP as CR 2013-19113, and corrective actions planned included the performance of a causal evaluation into the circumstances surrounding the work planning error. Because this finding was of very low safety significance and had been entered into the licensees CAP, the associated violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000346/2013005-02, Emergency Diesel Generator No.2 Rendered Unavailable By Scheduled Maintenance)

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Operability of Containment Hydrogen Analyzer Channels 1 and 2 following observed instrument spiking, as documented in CR 2013-17898, the week ending November 2, 2013;

• Operability of Containment and Environmental Equipment Qualification of equipment inside containment following identification of a main steam line break analysis deficiency, as documented in CR 2013-16627, the week ending November 2, 2013;

• Operability of HPI Train 1 with CCW isolated to Decay Heat Cooler Train 1, as documented in CR 2013-18597; and

• Operability of CV5011A, Containment Hydrogen Analyzer Sample Line 4 Inlet Valve 2, with degraded grease and taped connections, as documented in CR 2013-18612, the week ending November 23, 2013.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and Updated Safety Analysis Report (USAR) to the licensees evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.

Documents reviewed are listed in the Attachment to this report.

These operability inspections constituted four samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Plant Modification

a. Inspection Scope

The inspectors reviewed the following temporary modification to the facility:

• Engineering Change Package (ECP) No. 13-0178: Use of Dry Fuel Storage Facility Pad for 18 RFO Support Activities.

The inspectors reviewed the configuration changes and associated 10 CFR Part 50.59 and 10 CFR Part 72.48 safety evaluation documents against the design basis, the USAR, the Dry Fuel Storage System Certificate of Compliance, and the TS, as applicable, to verify that the modification did not affect the operability or availability of any safety-related systems, or systems important to safety. The inspectors observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; that the modification operated as expected; and that operation of the modification did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modifications with Operations, Engineering, and Training Department personnel to ensure that the individuals were aware of how the operation with the modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.

The inspectors review of this temporary plant modification constituted a single inspection sample as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing Activities

a. Inspection Scope

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

• Moisture Separator Drain Demineralizer No. 2 operational testing following heat exchanger replacement during the week ending October 12, 2013;

• Functional testing of No. 2 Condensate Pump following main electrical breaker replacement during the week ending October 26, 2013;

• Functional testing of motor-operated valve SW 1379 following multiple repairs to the valve actuator during the weeks ending October 26, 2013, and November 9, 2013;

• Operational testing of EDG No. 2 following a planned maintenance outage during the week ending November 2, 2013; and

• Functional testing of bus tie breaker ACDD2 following replacement during the week ending November 9, 2013.

These activities were selected based upon the system, structure or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with the PMTs to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety.

Documents reviewed are listed in the Attachment to this report.

The inspectors reviews of these activities constituted five PMT inspection samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

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

• Main turbine valve testing under procedures DB-SS-04150, DB-SS-04151, and DB-SS-04152 during the week ending October 26, 2013 (routine);

• Shield building core sample drilling during the weeks ending October 19, 2013, and October 26, 2013 (routine);

• DB-OP-03013; "Containment Daily Inspection & Containment Closeout Inspection," during the week ending December 7, 2013 (routine); and

• DB-SP-03446; Decay Heat Train 1 Pump and Valve Test (Modes 1-3), during the week ending October 26, 2013 (Inservice Testing [IST]).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• Did preconditioning occur;

• The effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• Acceptance criteria were clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• Plant equipment calibration was correct, accurate, and properly documented;

• Measuring and test equipment calibration was current;

• Test equipment was used within the required range and accuracy;

• applicable prerequisites described in the test procedures were satisfied;

• Test frequencies met TS requirements to demonstrate operability and reliability;

• Tests were performed in accordance with the test procedures and other applicable procedures;

• Jumpers and lifted leads were controlled and restored where used;

• Test data and results were accurate, complete, within limits, and valid;

• Test equipment was removed after testing;

• Where applicable for IST activities, testing was performed in accordance with the applicable version of Section XI, ASME code, and reference values were consistent with the system design basis;

• Where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• Prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• Equipment was returned to a position or status required to support the performance of its safety functions; and

• All problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

The inspectors reviews of these activities constituted three routine surveillance testing inspection samples and one inservice testing inspection sample as defined in IP 71111.22, Sections 02 and 05.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

.1 Annual Review of Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The Office of Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions to the EP and various Emergency Plan Implementing Procedures (EPIPs) located under ADAMS Accession Numbers ML13024A005, ML130070160, ML13071A555, ML13091A039, and ML13232A044, as listed in the Attachment to this report.

The licensee transmitted the EPIP revisions to the NRC pursuant to the requirements of 10 CFR Part 50, Appendix E, Section V, Implementing Procedures. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment to this report.

These reviews performed by the Office of Nuclear Security and Incident Response headquarters staff did not constitute any formal inspection samples.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on October 29, 2013, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

This inspection constituted a single complete sample as defined in IP 71124.01-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed all licensee performance indicators (PIs) for the Occupational Exposure Cornerstone for follow-up. The inspectors reviewed the results of Radiation Protection Program audits (e.g., licensees quality assurance (QA) audits or other independent audits). The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection. The inspectors reviewed the results of the audit and operational report reviews to gain insights into overall licensee performance.

b. Findings

No findings were identified.

.2 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether the licensee assessed the potential impact of these changes and has implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard.

The inspectors reviewed the last two radiological surveys from selected plant areas and evaluated whether the thoroughness and frequency of the surveys were appropriate for the given radiological hazard.

The inspectors conducted walkdowns of the facility, including radioactive waste processing, storage, and handling areas to evaluate material conditions and performed independent radiation measurements to verify conditions.

The inspectors selected the following radiologically risk significant work activities that involved exposure to radiation:

• Radiography;

• Emergency Core Cooling Sump Pump maintenance; and

• HPI Pump 2 quarterly surveillance.

For these work activities, the inspectors assessed whether the pre-work surveys performed were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if hazards were properly identified, including the following:

• Identification of hot particles;

• The presence of alpha emitters;

• The potential for airborne radioactive materials, including the potential presence of transuranics and/or other hard-to-detect radioactive materials;

• The hazards associated with work activities that could suddenly and severely increase radiological conditions and that the licensee has established a means to inform workers of changes that could significantly impact their occupational dose; and

• Severe radiation field dose gradients that can result in non-uniform exposures of the body.

The inspectors observed work in potential airborne areas and evaluated whether the air samples were representative of the breathing air zone. The inspectors evaluated whether continuous air monitors were located in areas with low background to minimize false alarms and were representative of actual work areas. The inspectors evaluated the licensees program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne.

b. Findings

No findings were identified.

.3 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors selected various containers holding non-exempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers, and assessed whether the containers were labeled and controlled in accordance with 10 CFR 20.1904, Labeling Containers, or met the requirements of 10 CFR 20.1905(g), Exemptions To Labeling Requirements.

The inspectors reviewed the following radiation work permits (RWPs) used to access high radiation areas and evaluated the specified work control instructions or control barriers:

• RWP 2013-7202, "Pre-outage Radiography at the Old Steam Generator Storage Facility," Revision 0;

• RWP 2013-1001, "Radiation Protection Activities," Revision 0; and

• RWP 2013-1002, "Operations Personnel Activities," Revision 0.

For these RWPs, the inspectors assessed whether allowable stay times or permissible dose (including from the intake of radioactive material) for radiologically significant work under each RWP were clearly identified. The inspectors evaluated whether electronic personal dosimeter alarm set points were in conformance with survey indications and plant policy.

The inspectors reviewed selected occurrences where a workers electronic personal dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether workers responded appropriately to the off-normal condition. The inspectors assessed whether the issue was included in the corrective action program and dose evaluations were conducted as appropriate.

For work activities that could suddenly and severely increase radiological conditions, the inspectors assessed the licensees means to inform workers of changes that could significantly impact their occupational dose.

b. Findings

No findings were identified.

.4 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors observed locations where the licensee monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures and whether the procedures were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site. The inspectors assessed whether the radiation monitoring instrumentation had appropriate sensitivity for the type(s) of radiation present.

The inspectors reviewed the licensees criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was guidance on how to respond to an alarm that indicates the presence of licensed radioactive material.

The inspectors reviewed the licensees procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors assessed whether or not the licensee has established a de facto release limit by altering the instruments typical sensitivity through such methods as raising the energy discriminator level or locating the instrument in a high radiation background area.

The inspectors selected several sealed sources from the licensees inventory records and assessed whether the sources were accounted for and verified to be intact.

The inspectors evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with 10 CFR 20.2207.

b. Findings

No findings were identified.

.5 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors evaluated ambient radiological conditions (e.g., radiation levels or potential radiation levels) during tours of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, RWPs, and worker briefings.

The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection (RP) job coverage (including audio and visual surveillance for remote job coverage), and contamination controls. The inspectors evaluated the licensees use of electronic personal dosimeters in high noise areas as high-radiation area monitoring devices.

The inspectors assessed whether radiation monitoring devices were placed on the individuals body consistent with licensee procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that the licensee properly employed an NRC approved method of determining effective dose equivalent.

The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in high radiation work areas with significant dose rate gradients.

The inspectors reviewed the following RWPs for work within airborne radioactivity areas with the potential for individual worker internal exposures:

• RWP 2013-1001, "Radiation Protection Activities", and

• RWP 2013-1002, "Operations Personnel Activities."

For these RWPs, the inspectors evaluated airborne radioactive controls and monitoring, including potential for significant airborne levels (e.g., grinding, grit blasting, system breaches, entry into tanks, cubicles, and reactor cavities). The inspectors assessed barrier (e.g., tent or glove box) integrity and temporary high efficiency particulate air ventilation system operation.

The inspectors examined the licensees physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within spent fuel and other storage pools. The inspectors assessed whether appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from the pool.

The inspectors examined the posting and physical controls for selected high radiation areas and very-high radiation areas to verify conformance with the occupational performance indicator.

b. Findings

No findings were identified.

.6 Risk Significant High Radiation Area and Very-High Radiation Area Controls (02.06)

a. Inspection Scope

The inspectors discussed with the RP manager the controls and procedures for high-risk high radiation areas and very-high radiation areas. The inspectors discussed methods employed by the licensee to provide stricter control of very-high radiation area access as specified in 10 CFR 20.1602, Control of Access to Very-High Radiation Areas, and Regulatory Guide 8.38, Control of Access to High and Very-High Radiation Areas of Nuclear Plants. The inspectors assessed whether any changes to licensee procedures substantially reduce the effectiveness and level of worker protection.

The inspectors discussed the controls in place for special areas that have the potential to become very-high radiation areas during certain plant operations with first-line health physics supervisors (or equivalent positions having backshift health physics oversight authority). The inspectors assessed whether these plant operations require communication beforehand with the health physics group, so as to allow corresponding timely actions to properly post, control, and monitor the radiation hazards including re-access authorization.

The inspectors evaluated licensee controls for very-high radiation areas and areas with the potential to become a very-high radiation area to ensure that an individual was not able to gain unauthorized access to the very-high radiation area.

b. Findings

No findings were identified.

.7 Radiation Worker Performance (02.07)

a. Inspection Scope

The inspectors observed radiation worker performance with respect to stated RP work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place, and whether their performance reflected the level of radiological hazards present.

The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be human performance errors. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. The inspectors discussed with the RP manager any problems with the corrective actions planned or taken.

b. Findings

No findings were identified.

.8 Radiation Protection Technician Proficiency (02.08)

a. Inspection Scope

The inspectors observed the performance of the RP technicians with respect to all RP work requirements. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits, and whether their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities.

The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be RP technician error. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.

b. Findings

No findings were identified.

.9 Problem Identification and Resolution (02.09)

a. Inspection Scope

The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring and exposure controls.

The inspectors assessed the licensees process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS2 Occupational As-Low-As-Reasonably-Achievable Planning and Controls

These inspection activities supplement those documented in NRC IR 05000346/2012003 and IR 05000346/2012005, and altogether constitute a single complete sample as defined in IP 71124.02-05.

.1 Source Term Reduction and Control (02.04)

a. Inspection Scope

The inspectors used licensee records to determine the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure. The inspectors assessed whether the licensee had made allowances or developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

These inspection activities supplement those documented in NRC IR 05000346/2013003, and altogether constitute a single complete sample as defined in IP 71124.06-05.

.1 Inspection Planning and Program Reviews (02.01)

a. Event Report and Effluent Report Reviews

(1) Inspection Scope The inspectors reviewed the radiological effluent release reports issued since the last inspection to determine if the reports were submitted as required by the Offsite Dose Calculation Manual/Technical Specifications. The inspectors reviewed anomalous results, unexpected trends, or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the CAP, and were adequately resolved.

The inspectors selected radioactive effluent monitor operability issues reported by the licensee as provided in effluent release reports, to review these issues during the onsite inspection, as warranted, given their relative significance and determine if the issues were entered into the CAP and adequately resolved.

(2) Findings No findings were identified.

b. Offsite Dose Calculation Manual and Final Safety Analysis Report Review

(1) Inspection Scope The inspectors reviewed USAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths so they could be evaluated during inspection walkdowns.

The inspectors reviewed changes to the Offsite Dose Calculation Manual made by the licensee since the last inspection against the guidance in NUREG 1301, 1302 and 0133, and Regulatory Guides 1.109, 1.21 and 4.1. When differences were identified, the inspectors reviewed the technical basis or evaluations of the change during the onsite inspection to determine whether they were technically justified and maintain effluent releases as-low-as-reasonably-achievable.

The inspectors reviewed licensee documentation to determine if the licensee has identified any non-radioactive systems that have become contaminated as disclosed either through an event report or the Offsite Dose Calculation Manual since the last inspection. This review provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59 evaluations and allowed a determination if any newly contaminated systems have an unmonitored effluent discharge path to the environment, whether any required Offsite Dose Calculation Manual revisions were made to incorporate these new pathways and whether the associated effluents were reported in accordance with Regulatory Guide 1.21.

(2) Findings No findings were identified.

c. Groundwater Protection Initiative Program

(1) Inspection Scope The inspectors reviewed reported groundwater monitoring results and changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

(2) Findings No findings were identified.

d. Procedures, Special Reports, and Other Documents

(1) Inspection Scope The inspectors reviewed Licensee Event Reports, event reports and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.

The inspectors reviewed effluent program implementing procedures, particularly those associated with effluent sampling, effluent monitor set point determinations, and dose calculations.

The inspectors reviewed copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the licensees program and aid in selecting areas for inspection review (smart sampling).

(2) Findings Failure to Maintain Written Procedures to Provide Quality Assurance for Effluent Monitoring Introduction The inspectors identified a finding of very low safety significance (Green) and an associated NCV of TS 5.4.1. Specifically, the licensee failed to revise procedures to assure full compliance with TS 5.5.3, Radioactive Effluent Controls Program, that limits the concentrations of radioactive material released in liquid effluents.

Description In May 2013, NRC inspectors requested information on tritium effluent concentration assessments to determine compliance with the TS 5.5.3, Radioactive Effluent Controls Program. The TS provides limits on the effluent program through the Off Site Dose Calculation Manual (ODCM) and procedures are developed and maintained to implement the ODCM and TS limits. Surveillance Test Procedure DB-OP-03011, Radioactive Liquid Batch Release is used to implement the ODCM limitations to plant effluents, including limits for tritium concentrations using monthly composites. The procedure was not maintained to limit tritium concentrations in compliance with TS 5.5.3, Radioactive Effluent Controls Program, that specifically limits tritium concentrations to those of 10 CFR Part 20, Appendix B, Table 2, Column 2.

Historically, the licensee has determined and reported tritium concentrations in liquid radioactive batch releases using a monthly composite, not specific individual batch releases. However, gamma isotopic activities were analyzed on a pre-release basis for each release, allowing the licensee to show compliance with the TS 5.5.3, Radioactive Effluent Controls Program, for gamma emitting isotopes.

In the early 1990s, the NRC revised 10 CFR Part 20, Appendix B, and many plants revised the TS to allow for a change in effluent concentrations. The licensee did not revise the TS 5.5.3, Radioactive Effluent Controls Program, thereby limiting the effluent concentration to 10 CFR Part 20, Appendix B, Table 2, Column 2. Additionally, the licensee did not amend procedures to assure compliance with the limited tritium concentrations. Specifically, DB-OP-03011, Radioactive Liquid Batch Release, the operating release procedure, did not outline the need for pre-release analysis of the tritium concentration for liquid batch releases. The procedure only required tritium analysis of the monthly batch composites to comply with ODCM requirements. A review of the monthly analysis data showed that the effluent concentrations did not exceed 10 times the regulatory limits.

Upon identification of this procedural inadequacy, the licensee established corrective actions in the form of a Chemistry Standing Order that ensures TS compliance with each liquid batch release by analyzing the tritium quantity in a batch release and limiting the batch flow rate. Procedure DB-OP-03011, Radioactive Liquid Batch Release, was subsequently amended to include these changes. The licensee is processing a TS amendment to change TS 5.5.3, Radioactive Effluent Controls Program, to align tritium effluent concentration limits with industry standards.

Analysis The failure to maintain procedures that require staff to perform analysis of tritium in individual batch releases and thereby, limit concentrations in the effluent of each release in accordance with TS 5.5.3, Radioactive Effluent Controls Program, constituted a performance deficiency that was reasonably within the licensee's ability to detect and correct and that should have been prevented.

The finding was not subject to traditional enforcement since the incident did not have a significant safety consequence, did not impact the NRCs ability to perform its regulatory function, and was not willful.

The inspectors reviewed the guidance in IMC 0612, Appendix E, Examples of Minor Issues, but did not identify any examples similar to the performance deficiency.

However, in accordance with IMC 0612, the inspectors determined that the finding was of more than minor significance because it affected the Public Radiation Safety Cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain, in that these conditions affected the attribute of program and process of projected offsite dose. The finding was assessed using IMC 0609, Attachment D, for the Public Radiation Safety SDP and determined to be of very low safety significance (Green) because it involved the Effluent Release Program but did not involve a failure to implement the program and did not involve a public dose greater than 10 CFR 50 Appendix I criterion or 10 CFR 20.1301(e). Corrective actions were developed by the licensee under CR 2013-07014, and senior plant management expressed the understanding that sampling was important and the condition would be corrected. The inspectors determined that no cross-cutting aspects applied to the performance deficiency, therefore no cross-cutting aspect was assigned.

Enforcement TS 5.4.1(c) requires written procedures be established, implemented, and maintained for quality assurance for effluent monitoring. The Surveillance Test Procedure, DB-OP-03011, Radioactive Liquid Batch Release, was used by the licensee to assure compliance with TS 5.5.3 that limits the tritium concentrations to those specified in 10 CFR Part 20, Appendix B, Table 2, Column 2.

Contrary to the above, as of May 3, 2013, the licensee failed to maintain Surveillance Test Procedure, DB-OP-03011 Radioactive Liquid Batch Release, to limit tritium concentration from batch effluent releases and show compliance with TS 5.5.3 Radioactive Effluent Controls Program. Because the licensee has documented this issue in their CAP as CR 2013-07014 and because the finding is of very low safety significance, the associated violation of TS 5.4.1(c) is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000346/2013005-03, Failure to Maintain Written Procedures to Provide Quality Assurance for Effluent Monitoring)

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the Reactor Coolant System (RCS)specific activity PI for Davis-Besse Nuclear Power Station for the period from the second quarter 2012 through the third quarter 2013. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees RCS chemistry samples, TS requirements, issue reports, event reports, and NRC Integrated IRs to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a RCS sample. Documents reviewed are listed in the Attachment to this report.

This inspection constituted a single reactor coolant system specific activity sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the occupational radiological occurrences PI for the period from the second quarter 2012 through the third quarter 2013. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine if indicator-related data was adequately assessed and reported. To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with RP staff the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas. Documents reviewed are listed in the Attachment to this report.

This inspection constituted a single occupational exposure control effectiveness sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the radiological effluent Technical Specification/Offsite Dose Calculation Manual (RETS/ODCM) radiological effluent occurrences PI for the period from the second quarter 2012 through the third quarter 2013. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods.

The inspectors reviewed the licensees issue report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the Attachment to this report.

This inspection constituted a single Radiological Effluent Technical Specification/Offsite Dose Calculation Manual radiological effluent occurrences sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.4 Reactor Coolant Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the RCS Leakage PI for the period from the second quarter 2012 through the third quarter 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, were used. The inspectors reviewed the licensees operator logs, RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection Reports for the period from October 2012 through September 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted a single reactor coolant system leakage sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline IPs discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily CR packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Follow-Up Sample for In-Depth Review: Shield Building Concrete Cracking Propagation

a. Inspection Scope

During the third quarter of 2013, the NRC completed an initial review of the licensees corrective actions to identify the causes for potential shield building laminar crack propagation (NRC IR 05000346/2013004, Section 4OA2.4; ADAMS Accession No. ML13308A283). As part of the NRCs continuing review of the licensee's ongoing actions in this area, an NRC structural inspector observed in-progress freeze/thaw testing on a previously removed core bore concrete sample. This testing was performed by the licensee's contractor at the University of Colorado - Boulder during the week of October 28, 2013. The inspector also reviewed test data and test data trending available at the time of the inspection. The purpose of the freeze/thaw test was to confirm or refute thermal cycling as a potential cause of laminar crack growth since 2011.

The inspection of this ongoing issue constituted only a partial follow-up inspection sample for in-depth review as defined in IP 71152-05. The full inspection sample is expected to be completed in early 2014.

b. Findings

No findings were identified.

.4 Annual Sample: Review of Operator Workarounds

a. Inspection Scope

The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds (OWAs) on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.

The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment to this report were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP and proposed or implemented appropriate and timely corrective actions which addressed each issue.

Reviews were conducted to determine if any operator challenge could increase the possibility of an initiating event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of mitigating systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified OWAs.

This review constituted a single operator workaround annual inspection sample as defined in IP 71152-05.

b. Findings

No findings were identified.

.5 Semi-Annual Trend Review: Low Level Communications Issues

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the six-month period of July 1 through December 31, 2013, although examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, QA audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted a single semi-annual trend inspection sample as defined in IP 71152-05.

b. Observations During the course of the review period for this inspection sample, the inspectors noted an increasing trend in the incidence of low level miscommunications experienced within the licensee's organization. Concurrent with this observed trend, the licensee has been ramping up the tempo of onsite work activity in preparation for their upcoming steam generator replacement and refueling outage, set to begin in the middle of the first quarter of 2014. Specific examples associated with this trend have included, but were not limited to:

• August 14, 2013: The inspectors identified a finding (FIN 05000346/2013004-01)associated with the failure to perform an accurate and detailed shift turnover.

The finding involved both written communications issues with the unit log, as well as verbal communications issues between the off going and on coming Operations shift crews. CR 2013-12633.

• October 30, 2013: While restoring CCW Train No. 2 to standby following EDG No. 2 PMT, an on-watch Reactor Operator directed an on-watch Equipment Operator to change CCW Heat Exchanger No. 2 Outlet Temperature Control Valve (SW 1434) set point to 85 °F instead of the 110 °F noted in the procedure being used to control the evolution. The SW 1434 valve went full open and a SW Train No. 2 pressure transient resulted (NCV 05000346/2013005-01).

CR 2013-17521.

• November 6, 2013: A contractor building scaffold in the Decay Heat Cooler Room received a momentary dose rate alarm, which was subsequently determined to have been inadvertently caused by use of a power drill in close proximity to the electronic dosimeter. When queried at an afternoon plant meeting, the duty RP supervisor reported that the individual receiving the alarm had self-identified the alarm and immediately exited the area. The following day that information was revised; the individual never heard the alarm, and it was identified during logout at the Radiological Restricted Area checkpoint.

• November 7, 2013: The published plant risk profile in the site's daily information package listed Instrument Air Dryers No. 1 and 2 out-of-service when they were not. The air dryer filters were merely bypassed for a normal periodic replacement. Additionally, Diverse Scram System testing and an associated plant power maneuver were not listed on the daily "Key Work" listing as a "Yellow" risk activity.

• November 20, 2013: Containment Hydrogen Analyzer Sample Line 4 Inlet Valve No. 2 (CV 5011A) was removed from service for routine preventative maintenance. During the maintenance CR 2013-18612 was generated which identified taped connections that do not meet EQ requirements. The on-shift crew was not informed of the condition; this was subsequently identified when Operations noticed that the CR needed SRO review later in the evening. By this point, however, CV 5011A had already been declared operable. Further miscommunications resulted during the supervisor review of the CR when a component engineer provided inaccurate guidance on the disposition of the cables in question. Altogether, the miscommunication incidents resulted in an unplanned TS entry and additional component inoperability time that could have been avoided. CRs 2013-18612; 2013-18759; and 2013-18681.

• December 2, 2013: The site's daily "Key Work" listed a sodium hypochlorite delivery as a "Yellow" risk activity for the day. The delivery had previously been rescheduled. CR 2013-19115.

• December 4, 2013: The site's daily "Key Work" listed circuit breaker BF313, the Motor Control Center F33 Normal Feeder, as being removed on that day. On December 3rd, issues with load testing Battery Charger No. 2PN resulted in the BF313 work being rescheduled, but the Work Week Manager was not informed.

• December 5, 2013: An increased "Yellow" risk heavy lifting activity associated with the station's receipt of new, replacement RCS hot leg piping was omitted from the site's daily "Key Work."

• December 19, 2013: The inspectors identified that an increased "Yellow" risk heavy lifting activity associated with the station's replacement steam generator support bases (weight of 24 tons each) was omitted from the site's daily "Key Work." CR 2013-19926.

While none of these miscommunication instances resulted in a significant miscue, the increasing tempo of preparation activities for the upcoming refuel outage represents a continuing communications challenge for the licensee.

c. Findings

No findings were identified.

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

.1 Event Notification 49546: All Control Room Annunciators in Alarm

a. Inspection Scope

The inspectors reviewed the plants response to a station annunciator system malfunction that caused all Control Room annunciator indications to be in alarm status on November 17, 2013. This condition resulted in a loss of normal audible and visual plant condition assessment capabilities and was assessed as being a significant loss of assessment capabilities by the licensee. Backup assessment capability was maintained by functionality of the Control Room alarm printer.

The inspectors reviewed the licensees response to the event, including but not limited to:

• Status of plant equipment and plant condition backup assessment capability;

• Non-emergency notifications made to state and local government agencies as required by 10 CFR 50.72; and

• Development and implementation of licensee repair plans.

Documents reviewed are listed in the Attachment to this report.

This event follow-up review constituted a single inspection sample as defined in IP 71153-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Review of the Plant Evaluation Report From the Institute of Nuclear Power Operations

As discussed in IMC 0612, Section 15.01, the inspectors completed a review of the report issued by the Institute of Nuclear Power Operations (INPO) for the most recent periodic plant evaluation performed at the Davis-Besse Nuclear Power Station during April 2013.

.2 Groundwater Sampling Results

a. Inspection Scope

The inspectors reviewed the results of groundwater samples taken from wells in the plant owner controlled area. The sampling of wells was completed as part of the licensees voluntary groundwater monitoring initiative. A sample taken on October 29, 2013, for one well located on the west side of the station's SW intake structure and designated MW-34S contained approximately 2,181 picocuries per liter (pCi/L) of tritium. Sample results above the 2,000 pCi/L groundwater monitoring program threshold require making courtesy notifications to state and local government officials and the NRC resident inspectors. These courtesy notifications were performed by the licensee on November 19, 2013, in accordance with their programmatic requirements after the laboratory results for the October 29th samples had been received and reviewed by station personnel. The formal reporting limit threshold is 30,000 pCi/L, as documented in the licensees Offsite Dose Calculation Manual.

The licensee had observed fluctuating concentrations of tritium in several monitoring wells in this same area during a previous sampling. The licensee continues to investigate and monitor wells in accordance with their groundwater monitoring program.

The inspectors reviewed the licensees compliance to their stated offsite agency reporting requirements.

These routine reviews for samples to detect tritium in groundwater did not constitute any additional inspection samples. Instead, they were considered as part of the inspectors daily plant status monitoring activities.

b. Findings

No findings were identified.

.3 (Closed) Unresolved Item 05000346/2013003-02; Evaluation of Out of Service and

Change in Flow Rates on Permanently Installed Radiation Monitors During routine inspection activities from April 29 to May 3, 2013, NRC inspectors identified that radiation monitors RE-1878B (Liquid Radioactive Waste Effluent -

Miscellaneous), RE-1822B (Waste Gas Decay System), and RE-1770 A and B (Liquid Radioactive Waste Effluent) had been out-of-service for extended periods over the past few years. These radiation monitors impact implementation of both the Off-site Dose Calculation Manual (ODCM) and the EP Program. Inspectors reviewed the potential effect the out-of-service time had on the EP Program and did not find sufficient evidence of a performance deficiency. The licensee staff implemented appropriate compensatory actions when these radiation monitors were out-of-service. The licensee did report the monitors out of service for greater than 30 days in the Annual Radioactive Effluent Release Report to the NRC in 2010, 2011, and 2012.

Additionally, radiation monitor RE-4598 Channel 1 had its calculated flow rate changed from 142,000 cubic feet per minute (CFM) to the 110,000 CFM (CR 2011-04083). The NRC inspectors reviewed this change in calculated flow rate and how it impacted the radiation monitors alert and alarm set point values. The flow rate changes did not have an impact on the radiation monitors EP emergency action level threshold values.

Further analysis by the licensee staff, reviewed by NRC inspectors, showed that monitoring of effluents from licensed activity remained conservative, and there were no significant changes to the EP Program Emergency Action Levels.

The licensee entered the issues into their CAP as CRs 2013-7209, 2013-07960, 2013-0869, and 2013-11808. Documents reviewed as part of this inspection are listed in the Attachment.

The inspectors did not identify a performance deficiency or violation of NRC requirements. Based on the inspectors review of the licensees analysis of the issue, this unresolved item is closed.

These reviews by the inspectors supplemented those documented in NRC IR 05000346/2013003, and as such did not constitute a separate inspection sample as defined in IP 71124.06-05.

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 14, 2014, the inspectors presented the inspection results to the Site Vice President, Mr. R. Lieb, and other members of the licensee staff. The licensee acknowledged the issues presented. Proprietary information reviewed by the inspectors was identified and were either returned to the licensee or verified as being controlled in accordance with applicable NRC policy and procedures regarding sensitive unclassified information.

.2 Interim Exit Meetings

Interim exits were conducted for:

• The inspection results for the areas of radiological hazard assessment and exposure controls; occupational as-low-as-reasonably-achievable (ALARA)planning and controls; radioactive gaseous and liquid effluent treatment; and RCS specific activity, occupational exposure control effectiveness, and RETS/ODCM radiological effluent occurrences PI verification with Mr. R. Lieb, the Site Vice President, on November 8, 2013 and a re-exit was conducted via telephone on January 27, 2014, with Mr. G. Wolf, the Regulatory Compliance Supervisor; and

• The licensed operator requalification training biennial written examination and annual operating test results with Mr. D. Hartnett, Operations Training Supervisor, on December 16, 2013, via telephone.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Proprietary information reviewed by the inspectors was identified and were either returned to the licensee or verified as being controlled in accordance with applicable NRC policy and procedures regarding sensitive unclassified information.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Lieb, Site Vice President

B. Boles, Director, Site Operations

K. Byrd, Director, Site Engineering

G. Cramer, Manager, Site Protection

J. Cuff, Manager, Training

J. Cunnings, Manager (Acting), Site Maintenance

A. Dawson, Manager, Chemistry

D. Hartnett, Superintendent, Operations Training

J. Hook, Manager, Design Engineering

D. Imlay, Director, Site Performance Improvement

G. Kendrick, Manager, Site Outage Management

B. Kremer, Manager, Plant Engineering

P. McCloskey, Manager, Site Regulatory Compliance

D. Noble, Manager, Radiation Protection

W. OMalley, Manager, Nuclear Oversight

R. Oesterle, Superintendent, Nuclear Operations

R. Patrick, Manager, Site Work Management

D. Petro, Manager, Steam Generator Replacement Project

T. Summers, Manager, Site Operations

M. Roelant, Manager, Site Projects

L. Rushing, Director, Special Projects

D. Saltz, Director, Site Maintenance

J. Sturdavant, Regulatory Compliance

L. Thomas, Manager, Nuclear Supply Chain

M. Travis, Superintendent, Radiation Protection

J. Vetter, Manager, Emergency Response

G. Wolf, Supervisor, Regulatory Compliance

K. Zellers, Supervisor, Reactor Engineering

Nuclear Regulatory Commission

J. Cameron, Chief, Branch 4, Division of Reactor Projects

Attachment

LIST OF ITEMS

Opened

05000346/2013005-01 NCV Operator Failure to Follow Procedure Results in Service Water System Transient (Section 1R11.3)

05000346/2013005-02 NCV Emergency Diesel Generator No.2 Rendered Unavailable By Scheduled Maintenance (Section 1R13.1)

05000346/2013005-03 NCV Failure to Maintain Written Procedures to Provide Quality Assurance for Effluent Monitoring (Section 2RS6.1)

Closed

05000346/2013005-01 NCV Operator Failure to Follow Procedure Results in Service Water System Transient (Section 1R11.3)

05000346/2013005-02 NCV Emergency Diesel Generator No.2 Rendered Unavailable By Scheduled Maintenance (Section 1R13.1)

05000346/2013005-03 NCV Failure to Maintain Written Procedures to Provide Quality Assurance for Effluent Monitoring (Section 2RS6.1)

05000346/2013003-02 URI Evaluation of Out of Service and Change in Flow Rates on Permanently Installed Radiation Monitors. (4OA5.1)

Discussed

None