IR 05000461/2013004

IR 05000461-13-004, 07/01/13 - 09/30/13, Clinton Power Station, Unit 1, Integrated Inspection Report, Operability Evaluations

ML13305A113
Person / Time
Site:	Clinton
Issue date:	10/31/2013
From:	Christine Lipa NRC/RGN-III/DRP/B1
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-13-004
Download: ML13305A113 (42)

Text

tober 31, 2013

SUBJECT:

CLINTON POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000461/2013004

Dear Mr. Pacilio:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station. The enclosed report documents the inspection results, which were discussed on October 3, 2013, with Mr. B. Taber and other members of your staff.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding was determined to involve a violation of NRC requirements. Because of the very low safety significance and since the finding was entered into your corrective action program, the NRC is treating the above inspector-identified violation as a Non-Cited Violation (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest 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 Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Clinton Power Station. In addition, if you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement to the Regional Administrator, Region III, and the NRC Resident Inspector at Clinton Power Station. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Christine A. Lipa, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62

Enclosure:

Inspection Report 05000461/2013004 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-461 License No: NPF-62 Report No: 05000461/2013004 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station, Unit 1 Location: Clinton, IL Dates: July 1 through September 30, 2013 Inspectors: W. Schaup, Senior Resident Inspector D. Lords, Resident Inspector S. Bell, Health Physicist J. Cassidy, Senior Health Physicist S. Mischke, Resident Inspector, Illinois Emergency Management Agency Approved by: C. Lipa, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000461/2013004, 07/01/13 - 09/30/13, Clinton Power Station, Unit 1,

Integrated Inspection Report, Operability Evaluations.

This report covers a three-month period of inspection by the resident inspectors and announced baseline inspections by regional inspectors. One Green finding, which had an associated non-cited violation, was identified. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using IMC 0609,

Significance Determination Process (SDP) 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 January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC-Identified

and Self Revealed Findings

Cornerstone: Mitigating Systems

Green.

An NRC identified non-cited violation of 10 CFR 50, Appendix B, Criterion V,

Instructions, Procedures and Drawings for the failure to follow procedure OP-AA-108-115, Operability Determinations, Revision 11, and document the basis that a reasonable expectation of operability existed after an immediate operability determination. Specifically, after the control room received a report of a crack on the after cooler ducting of the Division 2 emergency diesel generator the licensee failed to document their basis that a reasonable expectation of operability existed for the Division emergency diesel generator. The licensee documented this issue in the corrective action program as Action Request 015401540.

The inspectors determined that the licensees failure to follow the station procedure for operability determinations was a performance deficiency. Specifically, the licensee failed to follow the station procedure for operability determinations when they did not appropriately document the decision and the basis that a reasonable expectation of operability existed for the Division 2 emergency diesel generator upon discovery of a crack on the after cooler ducting. The performance deficiency is more than minor because if an immediate operability determination is made and either the basis that a reasonable expectation of operability exists or the declaration that the system, structure or component is inoperable is not appropriately documented it could lead to a more significant safety concern. Using Manual Chapter 0609, Attachment 4 Initial Characterization of Findings, and Appendix A The Significance Determination Process for Findings at Power the finding was screened against the mitigating systems cornerstone and determined to be of very low safety significance (Green) because the finding was/did not: 1) a deficiency affecting the design or qualification of a mitigating structure, system or component, 2) represent a loss of system and/or function, 3) represent an actual loss of function of a single train for greater than its technical specification allowed outage time, 4) represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event.

The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision making component, in that the licensees decisions failed to demonstrate that nuclear safety is an overriding priority. Specifically, the licensee failed to use their systematic process, when faced with an unexpected plant condition on the Division 2 emergency diesel generator to ensure safety was maintained.

H.1(a). (Section 1R15)

Licensee Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

Clinton Power Station (CPS), Unit 1 was operated at or near full power during the inspection period with the following exceptions:

• On July 28, 2013, the licensee reduced power to about 75 percent to perform control rod adjustments. The unit was returned to full power later the same day.

• On August 17, 2013, the licensee reduced power to about 71 percent to perform control rod sequence exchanges and surveillances on the main steam isolation valves, turbine stops valves combined intermediate valves, and turbine control valves. The unit was returned to full power the same day.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

• Control Room Ventilation train B during planned maintenance on Control Room Ventilation train A.

• Standby Gas Treatment System train B during planned maintenance on Standby Gas Treatment System train A.

• Division 2 Diesel Generator during planned maintenance on Division 3 Diesel Generator.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones. The inspectors reviewed operating procedures, system diagrams, Technical Specification (TS) requirements, and the impact of ongoing work activities on redundant trains of equipment. The inspectors verified that conditions did not exist 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 were aligned correctly and available as necessary.

In addition, the inspectors verified that equipment alignment problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

These activities constituted three partial system walkdown samples as defined in IP 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

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

• Fire Zone CB-1c Control Building Heating Ventilation And Cooling Equipment Area - Elevation 7190

• Fire Zone D-2 Diesel Generator Building Division 1 Diesel Fuel Tank Room -

Elevation 7120

• Fire Zone D-5a,b Diesel Generator Building Division 1 Diesel Generator and Day Tank Room - Elevation 7370

• Fire Zone CB-1(h) 702'-847' Control Building East Stairwell and Elevator Area

• Fire Zone CB-7 802'-0" Control Building Breathing Air Bottle Corridor 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 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.

In addition, the inspectors verified that fire protection related problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

These activities constituted five quarterly fire protection inspection samples as defined in IP 71111.05.

b. Findings

No findings were identified.

1R06 Flooding

.1 Underground Vaults

a. Inspection Scope

The inspectors selected underground bunkers/manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors determined that the cables were not submerged, that splices were intact, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as a sump pump, the device was operable and level alarm circuits were set appropriately to ensure that the cables would not be submerged. In those areas without dewatering devices, the inspectors verified that drainage of the area was available, or that the cables were qualified for submergence conditions. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following underground bunker/manhole subject to flooding:

• Screen House 1A underground vault

• Switch Yard 5 underground vault Specific documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one underground vaults sample as defined in IP 71111.06.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On September 11, 2013, the inspectors observed an evaluated scenario of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance;

• Crews clarity and formality of communications;

• Ability to take timely actions in the conservative direction;

• Prioritization, interpretation, and verification of annunciator alarms;

• Correct use and implementation of abnormal and emergency procedures;

• Control board manipulations;

• Oversight and direction from supervisors; and

• Ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.

This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

On August 17, 2013, the inspectors observed licensed operators reduce power and perform control rod sequence exchanges and surveillances on the main steam isolation valves, turbine stops/ combined intermediate valves and turbine control valves. These activities required heightened awareness, detailed planning and involved increased operational risk. The inspectors evaluated the following areas:

• Licensed operator performance;

• Crews clarity and formality of communications;

• Ability to take timely actions in the conservative direction;

• Prioritization, interpretation, and verification of annunciator alarms;

• Correct use and implementation of procedures;

• Control panel manipulations;

• Oversight and direction from supervisors; and

• Ability to identify and implement appropriate TS actions.

The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the licensee's handling of selected degraded performance issues involving the following risk-significant structures, systems, and components (SSCs):

• Diesel Generators The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the SSCs. Specifically, the inspectors independently verified the licensee's handling of SSC performance or condition problems in terms of:

• Appropriate work practices;

• Identifying and addressing common cause failures;

• Scoping of SSCs in accordance with 10 CFR 50.65(b);

• Characterizing SSC reliability issues;

• Tracking SSC unavailability;

• Trending key parameters (condition monitoring);

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

• Appropriateness of performance criteria for SSC functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSC functions classified (a)(1).

In addition, the inspectors verified that problems associated with the effectiveness of plant maintenance were entered into the licensee's corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted one maintenance effectiveness inspection samples as defined in IP 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

• Emergent work on RCIC trip/throttle valve on July 30, 2013

• Planned maintenance during the week of September 9-13 on the C Motor Driven Feed Water Pump Feed Water Regulating Valve

• Planned maintenance during the week of September 16-20 on Division 3 Emergency Diesel Generator

• C1R14 Shutdown Safety Management Program (Outage Risk Plan)

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 assumptions. 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.

In addition, the inspectors verified that problems associated with the effectiveness of plant maintenance were entered into the licensee's corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

a. Inspection Scope

The inspectors reviewed the following issues:

• A leak from the bottom of Reactor Core Isolation Cooling governor;

• A crack on the manifold to the after cooler on the Division 2 Emergency Diesel Generator;

• Turbine Bypass Valve number 2 and associated Core Operating Limit Report for thermal power limits;

• Division 3 Emergency Diesel Generator room ventilation damper did not operate as expected; and

• A loose latch up level link pin on the trip/throttle valve of the Reactor Core Isolation Cooling pump.

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 technical specifications and updated safety analysis report 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. When applicable, the inspectors also verified that the licensee appropriately assessed the functionality of SSCs that perform specified functions described in the UFSAR, Operations Requirements Manual, Emergency Plan, Fire Protection Plan, regulatory commitments, or other elements of the current licensing basis when degraded or nonconforming conditions were identified.

In addition, the inspectors verified that problems related to the operability or functionality of safety-related plant equipment were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted five samples as defined in IP 71111.15.

b. Findings

Introduction:

The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings for the failure to follow procedure OP-AA-108-115, Operability Determinations, Revision 11, and document the basis that a reasonable expectation of operability existed after an immediate operability determination. Specifically, after the control room received a report of a crack on the after cooler ducting of the Division 2 emergency diesel generator the licensee failed to document their basis that a reasonable expectation of operability existed for the Division 2 emergency diesel generator.

Description:

On July 30, 2013, at approximately 0930 the control room received initial notification of a degraded condition, a crack on the after cooler air duct, on the Division 2 emergency diesel generator. The issue was neither initially documented in accordance with the station corrective action procedure LS-AA-120, Issue Identification and Screening Process, Revision 14 nor documented in the operator logs in accordance with the station log keeping procedure OP-AA-111-101, Operating Narrative Logs and Records, Revision 8. Approximately ten and a half hours later an issue report was generated documenting the degraded condition and a log entry was made in the station logs at 2002 that a reasonable assurance of operability exists such that the Division 2 emergency generator remains operable and an operability evaluation has been requested to provide supporting operability documentation for the degraded condition.

On July 31, 2013, the inspectors challenged the on shift crew on why an immediate operability determination and the basis that a reasonable expectation of operability existed for the Division 2 emergency diesel generator had not been documented for over ten hours after the initial report to the control room. The control room supervisor explained and later documented on action request 01541540 that the shift manager was notified and extent of condition and fact finding progressed throughout the day to evaluate the degraded condition. The operations crew believed the emergency diesel generator was operable but had not documented it and the basis for operability in an issue report or in the station operation logs. Additionally the crew stated that even though a condition report had not been written they were using station procedure OP-AA-108-115-1002, Supplemental Consideration for On-shift Immediate Operability Determinations, Revision 2, Attachment 1 as part of the continual evaluation process.

Station procedure OP-AA-108-115, Operability Determinations, Revision 11, requires the licensee to determine and document the operability status of the affected system, structure or component in accordance with the corrective action program. The procedure additionally states, The focus of operability is foremost on the capability to ensure safety. Additionally the procedure states that operability should be determined immediately upon discovery that a system, structure or component subject to technical specifications is in a degraded or nonconforming condition. The determination should be made without delay and in a controlled manner using the best available information. The senior reactor operator should not postpone the determination until receiving the results of detailed evaluations. In most cases the decision can be made immediately and appropriately documented on the issue report.

The inspectors determined that the licensee failed to follow the station procedure for operability determinations because the issue was neither initially documented in an action request as required nor documented in the operator logs as required and as part of the immediate operability determination process, the basis for why a reasonable expectation of operability existed for the Division 2 emergency diesel generator was not appropriately documented.

The licensee has put in place interim corrective actions in the form of an operations standing order that states When a significant piece of safety related equipment is identified to have a degraded condition that is not yet documented in an issue request, the operability or inoperability needs to be documented in the main control room narrative logs within approximately 15 minutes of the notification to the main control room or shift management.

Analysis:

The inspectors determined that the licensee failing to follow the station procedure for operability determinations was a performance deficiency. Specifically, the licensee failed to follow the station procedure for operability determinations and appropriately document the decision and the basis that a reasonable expectation of operability existed for the Division 2 emergency diesel generator. The performance deficiency is more than minor because if an immediate operability determination is made and either the basis that a reasonable expectation of operability exists or the declaration that the system, structure or component is inoperable is not appropriately documented it could lead to a more significant safety concern. Using Manual Chapter 0609, 4 Initial Characterization of Findings, and Appendix A The Significance Determination Process for Findings at Power the finding was screened against the mitigating systems cornerstone and determined to be of very low safety significance (Green) because the finding was/did not: 1) a deficiency affecting the design or qualification of a mitigating structure, system or component, 2) represent a loss of system and/or function, 3) represent an actual loss of function of a single train for greater than its technical specification allowed outage time, 4) represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision making component, in that the licensee decisions failed to demonstrate that nuclear safety is an overriding priority.

Specifically, the licensee failed to use their systematic process, when faced with an unexpected plant condition on the Division 2 emergency diesel generator to ensure safety was maintained. H.1(a). (Section 1R15)

Enforcement:

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires in part, that activities affecting quality shall be accomplished in accordance with instructions , procedures or drawings, appropriate to the circumstance.

Station procedure OP-AA-108-115, Operability Determinations, Revision 11, Step 4.1.6 states, in part, In most cases the decision can be made immediately and appropriately documented on the issue report. Contrary to this, on July 30, 2013, the licensee failed to follow the station procedure for operability determinations and appropriately document the decision and the basis that a reasonable expectation of operability existed for the Division 2 emergency diesel generator. Because this violation is of very low safety significance and was entered into the corrective action program as action request AR 01541540, this violation is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000461/2013004-01, Failure to Follow Procedure and Appropriately Document Basis for Immediate Operability of the Division 2 Emergency Diesel Generator.

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors reviewed the following modification:

• Alternate Shutdown Level Instrumentation, Engineering Change 389496 The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the updated safety analysis report, and the technical specifications, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications 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 modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance.

This inspection constituted one permanent plant modification sample as defined in IP 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

• Emergent work on Reactor Core Isolation Cooling pump trip/throttle valve;

• Service Water A pump and motor after maintenance activities;

• Division I Shutdown Service Water motor operated valve operation and thrust verification post maintenance tests;

• Bus 1B1 main feed breaker and reserve feed breaker synch-relay replacement post maintenance test;

• Emergent work on Division 3 Diesel Generator Room Cooling Exhaust Damper; and

• Division 3 Diesel Generator after voltage regulator testing.

The inspectors reviewed the scope of the work performed and evaluated the adequacy of the specified post-maintenance testing. The inspectors verified that the post-maintenance testing was performed in accordance with approved procedures; that the procedures contained clear acceptance criteria, which demonstrated operational readiness and that the acceptance criteria was met; that appropriate test instrumentation was used; that the equipment was returned to its operational status following testing; and, that the test documentation was properly evaluated.

In addition, the inspectors reviewed corrective action program documents associated with post-maintenance testing to verify that identified problems were entered into the licensee's corrective action program with the appropriate characterization. Selected action requests were reviewed to verify that the corrective actions were appropriate and implemented as scheduled.

This inspection constituted six post-maintenance testing sample as defined in IP 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

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

• CPS 9052.01, Residual Heat Removal A Pump Operability (Routine Test)

• CPS 9054.01C002, Reactor Core Isolation Cooling High Pressure Operability Checks (In-service Test)

• CPS 9051.01, High Pressure Core Spray Pump Operability (In-service test)

• CPS 9080.03, Diesel Generator 1C Operability (Routine Test)

• CPS 9080.13, Diesel Generator 1B 24 Hour and Hot Restart (In-service Test)

The inspectors observed selected portions of the test activities to verify that the testing was accomplished in accordance with plant procedures. The inspectors reviewed the test methodology and documentation to verify that equipment performance was consistent with safety analysis and design basis assumptions, and that testing acceptance criteria were satisfied.

In addition, the inspectors verified that surveillance testing problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted two routine surveillance testing samples and three in-service testing samples for a total of five samples as defined in IP 71111.22.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a full scale emergency preparedness drill on August 6, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. This drill was planned to be evaluated and was included in performance indicator data regarding drill and exercise performance. The inspectors observed emergency response operations in the control room simulator and 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.

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

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

This inspection constituted one complete sample as defined in Inspection Procedure (IP)71124.05-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the plant Final Safety Analysis Report (FSAR) to identify radiation instruments associated with monitoring area radiological conditions including airborne radioactivity, process streams, effluents, materials/articles, and workers.

Additionally, the inspectors reviewed the instrumentation and the associated Technical Specification (TS) requirements for post-accident monitoring instrumentation including instruments used for remote emergency assessment.

The inspectors reviewed a listing of in-service survey instrumentation including air samplers and small article monitors, along with instruments used to detect and analyze workers external contamination. Additionally, the inspectors reviewed personnel contamination monitors and portal monitors, including whole-body counters, to detect workers internal contamination. The inspectors reviewed this list to assess whether an adequate number and type of instruments were available to support operations.

The inspectors reviewed licensee and third-party evaluation reports of the Radiation Monitoring Program since the last inspection. These reports were reviewed for insights into the licensees program and to aid in selecting areas for review (smart sampling).

The inspectors reviewed procedures that govern instrument source checks and calibrations, focusing on instruments used for monitoring transient high radiological conditions, including instruments used for underwater surveys. The inspectors reviewed the calibration and source check procedures for adequacy and as an aid to smart sampling.

The inspectors reviewed the area radiation monitor alarm setpoint values and setpoint bases as provided in the TSs and the FSAR.

The inspectors reviewed effluent monitor alarm setpoint bases and the calculational methods provided in the offsite dose calculation manual (ODCM).

b. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down effluent radiation monitoring systems, including at least one liquid and one airborne system. Focus was placed on flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors of the selected systems. The inspectors assessed whether the effluent/process monitor configurations aligned with ODCM descriptions and observed monitors for degradation and out-of-service tags.

The inspectors selected portable survey instruments that were in use or available for issuance and assessed calibration and source check stickers for currency as well as instrument material condition and operability.

The inspectors observed licensee staff performance as the staff demonstrated source checks for various types of portable survey instruments. The inspectors assessed whether high-range instruments were source checked on all appropriate scales.

The inspectors walked down area radiation monitors and continuous air monitors to determine whether they were appropriately positioned relative to the radiation sources or areas they were intended to monitor. Selectively, the inspectors compared monitor response (via local or remote control room indications) with actual area conditions for consistency.

The inspectors selected personnel contamination monitors, portal monitors, and small article monitors and evaluated whether the periodic source checks were performed in accordance with the manufacturers recommendations and licensee procedures.

b. Findings

No findings were identified.

.3 Calibration and Testing Program (02.03)

Process and Effluent Monitors

a. Inspection Scope

The inspectors selected effluent monitor instruments (such as gaseous and liquid) and evaluated whether channel calibration and functional tests were performed consistent with radiological effluent TSs/ODCM. The inspectors assessed whether:

(a) the licensee calibrated its monitors with National Institute of Standards and Technology traceable sources;

(b) the primary calibrations adequately represented the plant nuclide mix;

(c) when secondary calibration sources were used, the sources were verified by the primary calibration; and

(d) the licensees channel calibrations encompassed the instruments alarm set-points.

The inspectors assessed whether the effluent monitor alarm setpoints were established as provided in the ODCM and station procedures.

For changes to effluent monitor setpoints, the inspectors evaluated the basis for changes to ensure that an adequate justification existed.

b. Findings

No findings were identified.

Laboratory Instrumentation

a. Inspection Scope

The inspectors assessed laboratory analytical instruments used for radiological analyses to determine whether daily performance checks and calibration data indicated that the frequency of the calibrations was adequate and there were no indications of degraded instrument performance.

The inspectors assessed whether appropriate corrective actions were implemented in response to indications of degraded instrument performance.

b. Findings

No findings were identified.

Whole Body Counter

a. Inspection Scope

The inspectors reviewed the methods and sources used to perform whole body count functional checks before daily use of the instrument and assessed whether check sources were appropriate and aligned with the plants isotopic mix.

The inspectors reviewed whole body count calibration records since the last inspection and evaluated whether calibration sources were representative of the plant source term and that appropriate calibration phantoms were used. The inspectors looked for anomalous results or other indications of instrument performance problems.

b. Findings

No findings were identified.

Post-Accident Monitoring Instrumentation

a. Inspection Scope

The inspectors selected containment high-range monitors and reviewed the calibration documentation since the last inspection.

The inspectors assessed whether an electronic calibration was completed for all range decades above 10 rem/hour and whether at least one decade at or below 10 rem/hour were calibrated using an appropriate radiation source.

The inspectors assessed whether calibration acceptance criteria were reasonable; accounting for the large measuring range and the intended purpose of the instruments.

The inspectors selected effluent/process monitors that were relied on by the licensee in its emergency operating procedures as a basis for triggering emergency action levels and subsequent emergency classifications, or to make protective action recommendations during an accident. The inspectors evaluated the calibration and availability of these instruments.

The inspectors reviewed the licensees capability to collect high-range, post-accident iodine effluent samples.

As available, the inspectors observed electronic and radiation calibration of these instruments to assess conformity with the licensees calibration and test protocols.

b. Findings

No findings were identified.

Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors

a. Inspection Scope

For each type of these instruments used onsite, the inspectors assessed whether the alarm setpoint values were reasonable under the circumstances to ensure that licensed material is not released from the site.

The inspectors reviewed the calibration documentation for each instrument selected and discussed the calibration methods with the licensee to determine consistency with the manufacturers recommendations.

b. Findings

No findings were identified.

Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air Samplers/Continuous Air Monitors

a. Inspection Scope

The inspectors reviewed calibration documentation for at least one of each type of instrument. For portable survey instruments and area radiation monitors, the inspectors reviewed detector measurement geometry and calibration methods and had the licensee demonstrate use of its instrument calibrator as applicable. The inspectors conducted comparison of instrument readings versus an NRC survey instrument if problems were suspected.

As available, the inspectors selected portable survey instruments that did not meet acceptance criteria during calibration or source checks to assess whether the licensee has taken appropriate corrective action for instruments found significantly out of calibration (i.e., greater than 50 percent). The inspectors evaluated whether the licensee evaluated the possible consequences of instrument use since the last successful calibration or source check.

b. Findings

No findings were identified.

Instrument Calibrator

a. Inspection Scope

As applicable, the inspectors reviewed the current output values for the licensees portable survey and area radiation monitor instrument calibrator unit(s). The inspectors assessed whether the licensee periodically measures calibrator output over the range of the instruments used through measurements by ion chamber/electrometer.

The inspectors assessed whether the measuring devices had been calibrated by a facility using National Institute of Standards and Technology traceable sources and whether corrective factors for these measuring devices were properly applied by the licensee in its output verification.

b. Findings

No findings were identified.

Calibration and Check Sources

a. Inspection Scope

The inspectors reviewed the licensees 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, source term to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

b. Findings

No findings were identified.

4. Problem Identification and Resolution (02.04)

a. Inspection Scope

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

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

This inspection constituted one complete sample as defined in Inspection Procedure (IP)71124.06-05.

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. 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 (ODCM/TS). 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 corrective action program, and were adequately resolved.

The inspectors identified 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 corrective action program and adequately resolved.

b. Findings

No findings were identified.

Offsite Dose Calculation Manual and Final Safety Analysis Report Review

a. Inspection Scope

The inspectors reviewed Final Safety Analysis Report (FSAR) 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 ODCM 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-is-reasonably-achievable (ALARA).

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 ODCM 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 ODCM revisions were made to incorporate these new pathways, and whether the associated effluents were reported in accordance with Regulatory Guide 1.21.

b. Findings

No findings were identified.

Groundwater Protection Initiative Program

a. 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.

b. Findings

No findings were identified.

Procedures, Special Reports, and Other Documents

a. 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).

b. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down selected components of the gaseous and liquid discharge systems to evaluate whether equipment configuration and flow paths align with the documents reviewed in 02.01 above and to assess equipment material condition.

Special attention was made to identify potential unmonitored release points such as open roof vents in boiling water reactor turbine decks, temporary structures butted against turbine, auxiliary or containment buildings, building alterations which could impact airborne, or liquid effluent controls, and ventilation system leakage that communicates directly with the environment.

For equipment or areas associated with the systems selected for review that were not readily accessible due to radiological conditions, the inspectors reviewed the licensee's material condition surveillance records, as applicable.

The inspectors walked down filtered ventilation systems to assess for conditions such as degraded high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system.

As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluent (including sample collection and analysis) to evaluate whether appropriate treatment equipment was used and the processing activities align with discharge permits.

The inspectors determined if the licensee has made significant changes to their effluent release points (e.g., changes subject to a 10 CFR 50.59 review or require NRC approval of alternate discharge points.)

As available, the inspectors observed selected portions of the routine processing and discharge liquid waste (including sample collection and analysis) to determine if appropriate effluent treatment equipment is being used and that radioactive liquid waste is being processed and discharged in accordance with procedure requirements and aligns with discharge permits.

b. Findings

No findings were identified.

.3 Sampling and Analyses (02.03)

a. Inspection Scope

The inspectors selected effluent sampling activities, consistent with smart sampling, and assessed whether adequate controls have been implemented to ensure representative samples were obtained (e.g., provisions for sample line flushing, vessel recirculation, composite samplers, etc.)

The inspectors selected effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors to assess whether controls were in place to ensure compensatory sampling was performed consistent with the radiological effluent TS/ODCM and that those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the Inter-Laboratory Comparison Program to evaluate the quality of the radioactive effluent sample analyses and assessed whether the Inter-Laboratory Comparison Program includes hard-to-detect isotopes as appropriate.

b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

a. Inspection Scope

The inspectors reviewed the methodology the licensee uses to determine the effluent stack and vent flow rates to determine if the flow rates were consistent with radiological effluent TS/ODCM or FSAR values, and differences between assumed and actual stack and vent flow rates did not affect the results of the projected public doses.

b. Findings

No findings were identified.

Air Cleaning Systems

a. Inspection Scope

The inspectors assessed whether surveillance test results since the previous inspection for TS required ventilation effluent discharge systems (high-efficiency particulate air and charcoal filtration), such as the Standby Gas Treatment System and the Containment/Auxiliary Building Ventilation System, met TS acceptance criteria.

b. Findings

No findings were identified.

.5 Dose Calculations (02.05)

a. Inspection Scope

The inspectors reviewed all significant changes in reported dose values compared to the previous radiological effluent release report (e.g., a factor of five, or increases that approach Appendix I criteria) to evaluate the factors which may have resulted in the change.

The inspectors reviewed radioactive liquid and gaseous waste discharge permits to assess whether the projected doses to members of the public were accurate and based on representative samples of the discharge path.

The inspectors evaluated the methods used to determine the isotopes that are included in the source term to ensure all applicable radionuclides are included within detectability standards. The review included the current Part 61 analyses to ensure hard-to-detect radionuclides are included in the source term.

The inspectors reviewed changes in the licensees offsite dose calculations since the last inspection to evaluate whether changes were consistent with the ODCM and Regulatory Guide 1.109. The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to evaluate whether appropriate factors were being used for public dose calculations.

The inspectors reviewed the latest Land Use Census to assess whether changes (e.g.,

significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of nearest member of the public, or critical receptor, etc.) have been factored into the dose calculations.

For the releases reviewed above, the inspectors evaluated whether the calculated doses (monthly, quarterly, and annual dose) are within the 10 CFR Part 50, Appendix I, and TS dose criteria.

The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages, were reviewed to ensure that an evaluation was made of the discharge to satisfy 10 CFR 20.1501 so as to account for the source term and projected doses to the public.

b. Findings

No findings were identified.

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the Groundwater Protection Initiative to determine if the licensee had implemented its program, as intended, and to identify any anomalous results. For anomalous results or missed samples, the inspectors assessed whether the licensee had identified and addressed deficiencies through its corrective action program.

The inspectors reviewed identified leakage or spill events and entries made into 10 CFR 50.75

(g) records. The inspectors reviewed evaluations of leaks or spills and reviewed any remediation actions taken for effectiveness. The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and mitigated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by:

• Assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and the radiological source term and assessing whether a survey/evaluation had been performed to include consideration of hard-to-detect radionuclides.

• Determining whether the licensee completed offsite notifications, as provided in its Groundwater Protection Initiative implementing procedures.

The inspectors reviewed the evaluation of discharges from onsite surface water bodies that contain or potentially contain radioactivity, and the potential for ground water leakage from these onsite surface water bodies. The inspectors assessed whether the licensee was properly accounting for discharges from these surface water bodies as part of their effluent release reports.

The inspectors assessed whether onsite ground water sample results and a description of any significant onsite leaks/spills into ground water for each calendar year were documented in the Annual Radiological Environmental Operating Report for the Radiological Environmental Monitoring Program or the Annual Radiological Effluent Release Report for the Radiological Effluent TSs.

For significant, new effluent discharge points (such as significant or continuing leakage to ground water that continues to impact the environment if not remediated), the inspectors evaluated whether the ODCM was updated to include the new release point.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

Inspectors assessed whether problems associated with the Effluent Monitoring and Control Program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees corrective action program. In addition, they evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls.

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 discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, are not discussed in this report.

These routine reviews for the identification and resolution of problems did not constitute any inspection sample as defined in IP 71152.

b. Findings

No findings were identified.

.2 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 by reviewing 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 corrective action program and proposed or implemented appropriate and timely corrective actions which addressed each issue. Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.

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

b. Findings

No findings were identified.

.3 Annual In-depth Review Samples

a. Inspection Scope

After being notified of a fire in the containment building, the inspectors selected the following action request for in-depth review:

• AR 015241901, Construction Debris Ignited The inspectors verified the following attributes during their review of the licensee's corrective actions for the above action request and other related action requests:

• Complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;

• Consideration of the extent of condition, generic implications, common cause and previous occurrences;

• Evaluation and disposition of operability and if the issue was reportable;

• Classification and prioritization of the resolution of the problem, commensurate with safety significance;

• Identification of the root and contributing causes of the problem; and

• Identification of corrective actions, which were appropriately focused to correct the problem.

The inspectors discussed the corrective actions and associated action request evaluations with licensee personnel.

This inspection constituted one annual in-depth review inspection samples as defined in IP 71152.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Resident Inspector Exit Meeting

On October 3, 2013, the inspectors presented the inspection results to Mr. B. Taber and other members of the licensee staff. The licensee acknowledged the issues presented.

Proprietary information was examined during this inspection but is not specifically discussed in this report.

.2 Interim Exit Meetings

Interim exit meetings were conducted for:

• The Radioactive Gaseous and Liquid Effluent Treatment inspection results were discussed with Mr. R. Schenck, Acting Plant Manager, and other members of the plant staff on August 9, 2013.

• The inspection results for the area of radiation monitoring instrumentation were discussed with Mr. B. Taber, Site Vice President, on September 20, 2013.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Bair, Chemistry Manager

K. Baker, Regulatory Assurance Manager

J. Bond, Emergency Preparedness Manager

R. Campbell, RP Technical Manager

J. Cunningham, Operations Director

C. Dunn, Training Director

R. Frantz, Regulatory Assurance

M. Friedman, Radiation Protection Operations Manager

N. Hightower, Radiation Protection Manager

T. Krawcyk, Shift Operations Superintendent

K. Leffel, Operations Support Manager

D. Kemper, Engineering Director

S. Kowalski, Senior Manager Design Engineering

M. Mayer, Acting Security Manager

S. Mohundro, Engineering Programs Manager

W. Padgett, Work Management

F. Sarantakos, Engineering Programs

R. Schenck, Work Management Director

D. Shelton, Operations Services Manager

D. Smith, Design Engineering

J. Smith, Senior Manager Plant Engineering

D. Snook, Operations Training Manager

T. Stoner, Plant Manager

J. Stovall, Maintenance Director

B. Taber, Site Vice President

R. Zacholski, Acting Nuclear Oversight Manager

Attachment

LIST OF ITEMS

Opened/Closed

05000461/2013004-01 NCV Failure to Follow Procedure and Appropriately Document Basis for Immediate Operability of the Division 2 Emergency Diesel Generator (Section 1R15)

Closed

None

Discussed

None Attachment