Text

IR 05000298-11-006; 6/6/2011 - 6/24/2011; Cooper Nuclear Station, Biennial Baseline Inspection of the Identification and Resolution of Problems
	ML112201499
Person / Time
Site:	Cooper
Issue date:	08/08/2011
From:	Powers D; Division of Reactor Safety IV
To:	O'Grady B; Nebraska Public Power District (NPPD)
References
	EA-11-176 IR-11-006
	Download: ML112201499 (41)
	v • d • e

UNITED STATES

NUC LE AR RE G ULATO RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

August 8, 2011

EA-2011-176

Brian J. OGrady, Vice President-Nuclear

and Chief Nuclear Officer

Nebraska Public Power District

Cooper Nuclear Station

72676 648A Avenue

Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION REPORT 05000298/2011006 AND NOTICE OF

VIOLATION

Dear Mr. OGrady:

On June 24, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Cooper Nuclear Station. The enclosed report documents the inspection findings, which

were discussed on June 24, 2011, with you and other members of your staff.

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

and resolution of problems, safety and compliance with the Commissions rules and regulations

and with the conditions of your operating license. The inspectors reviewed selected procedures

and records, observed activities, and interviewed personnel. The inspectors also interviewed a

representative sample of personnel regarding the condition of your safety conscious work

environment.

The inspectors concluded that Cooper Nuclear Station generally identified, evaluated, and

corrected problems according to their safety significance. Cooper Nuclear Station generally

analyzed operating experience appropriately, performed effective self-assessments, and

maintained an effective safety conscious work environment.

The inspectors identified weaknesses in the areas of operability evaluations, thorough

evaluations, and the effectiveness of corrective actions. This was evidenced most notably

by repetitive diesel failures in 2009. The inspectors noted that the previous Problem

Identification and Resolution inspection, documented in weaknesses in operability evaluations

and that some root causes should have been more thorough. Therefore, the inspectors

considered the weaknesses in operability evaluations and thorough evaluations to be repetitive

weaknesses.

Based on the results of the inspection, the NRC has identified an issue that was evaluated

under the risk significance determination process as having very low safety significance

(Green). The NRC has also determined that one violation is associated with this issue. The

violation is being cited because Cooper Nuclear Station failed to restore compliance with

Nebraska Public Power District -2-

NRC requirements within a reasonable time after a previous violation was identified in NRC

Inspection Report 05000298/2010007 (issued December 3, 2010). This is consistent with the

NRC Enforcement Policy; Section 2.3.2, which states, in part, that a cited violation will be

considered if the licensee fails to restore compliance within a reasonable time after a violation is

identified.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

Based on the results of the inspection, the NRC has also identified that two NRC-identified

issues that were evaluated under the risk significance determination process as having very low

safety significance (Green) and two Severity Level IV violations of NRC requirements occurred.

All of these findings were determined to involve violations of NRC requirements. However,

because of the very low safety significance of the violations and because they were entered into

your corrective action program, the NRC is treating these violations as noncited violations

consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest these violations or the characterization of the violations, 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 copies to the Regional Administrator, U.S. Nuclear Regulatory Commission,

Region IV, 612 East Lamar Blvd., Suite 400, Arlington, Texas, 76011-4125; the Director, Office

of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001;

and the NRC Resident Inspector at Cooper Nuclear 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 IV, and the NRC Resident Inspector at your facility.

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

enclosure, and your response will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web-site at

www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Dr. Dale A. Powers, Acting Chief and Senior

Technical Analyst

Technical Support Branch

Division of Reactor Safety

Dockets: 50-298

License: DRP-46

Nebraska Public Power District -3-

Enclosure 1 - Notice of Violation

Enclosure 2 - Inspection Report 05000298/2011006 w/Attachments:

Attachment 1 - Supplemental Information

Attachment 2 - Initial Information Request

Attachment 3 - Supplemental Information Request

cc w/ Enclosure:

Distribution via Listserv

Nebraska Public Power District -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director (Jeff.Clark@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

Acting DRS Director (Robert.Caldwell@nrc.gov)

DRS Deputy Director (Tom.Blount@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Michael.Chambers@nrc.gov)

Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)

Project Engineer, DRP/C (Jonathan.Braisted@nrc.gov)

Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov)

CNS Administrative Assistant (Amy.Elam@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Lynnea.Wilkins@nrc.gov)

Acting Branch Chief, DRS/TSB (Dale.Powers@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

ACES (Ray.Kellar@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

RIV/ETA: OEDO (John.McHale@nrc.gov)

DRS/TSB STA (Dale.Powers@nrc.gov)

SUNSI Rev Compl. ;Yes No ADAMS ;Yes No Reviewer Initials DAP

Publicly Avail ;Yes No Sensitive Yes ; No Sens. Type Initials DAP

RI:DRP/A DRP/C RI:DRS/EB2 RI:DRS/PSB2 C:DRP/PBC

BTindell JJosey NOkonkwo IAnchondo VGaddy

/RA/ /RA/ /RA/ /RA/ E /RA/

7/25/2011 7/28/2011 7/25/2011 7/28/2011 7/29/2011

ACES C:DRS/TSB

RKellar DPowers

/RA/ /RA/

8/5/2011 8/8/2011

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NOTICE OF VIOLATION

Nebraska Public Power District Docket No. 50-298

Cooper Nuclear Station License No. DPR-46

EA-2011-176

During an NRC inspection conducted June 6 through June 24, 2011, a violation of NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, measures

shall be established to assure that applicable regulatory requirements and the design

basis, as defined in 10 CFR 50.2 and as specified in the license application, for those

components to which this appendix applies, are correctly translated into specifications,

drawings, procedures, and instructions.

Contrary to the above, since December 3, 2010, the licensee failed to assure that

applicable regulatory requirements and the design basis were correctly translated into

specifications, drawings, procedures, and instructions. Specifically, the licensee failed to

correctly translate regulatory and design basis requirements, associated with tornado

and high wind generated missiles, into design information necessary to protect the

emergency diesel generator fuel oil day tank vent line components.

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is hereby required

to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional

Administrator, Region IV, 612 East Lamar Blvd., Suite 400, Arlington, Texas, 76011-4125 and a

copy to the NRC Resident Inspector at Cooper Nuclear Station, within 30 days of the date of the

letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a

"Reply to a Notice of Violation; EA-2011-176" and should include: (1) the reason for the

violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective

steps that have been taken and the results achieved, (3) the corrective steps that will be taken,

and (4) the date when full compliance will be achieved. Your response may reference or

include previous docketed correspondence, if the correspondence adequately addresses the

required response. If an adequate reply is not received within the time specified in this Notice,

an order or a Demand for Information may be issued as to why the license should not be

modified, suspended, or revoked, or why such other action as may be proper should not be

taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

-1- Enclosure 1

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

Dated this 8th day of August 2011.

-2- Enclosure 1

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000298

License: DRP-46

Report: 05000298/2011006

Licensee: Nebraska Public Power District

Facility: Cooper Nuclear Station

Location: 72676 648A Ave.

Brownville, NE 68321

Dates: June 6 through June 24, 2011

Team Leader: B. Tindell, Senior Reactor Inspector

Inspectors: I. Anchondo, Reactor Inspector

J. Josey, Senior Resident Inspector

N. Okonkwo, Reactor Inspector

Approved By: Dr. Dale A. Powers

Acting Chief and Senior Technical Analyst

Technical Support Branch

Division of Reactor Safety

-1- Enclosure 2

SUMMARY OF FINDINGS

IR 05000298/2011006; 6/6/2011 - 6/24/2011; Cooper Nuclear Station, Biennial Baseline

Inspection of the Identification and Resolution of Problems.

A senior reactor inspector, two reactor inspectors, and a senior resident inspector performed the

inspection. In this report, the inspectors documented two noncited violations of very low safety

significance (Green), two severity level IV noncited violations, and one cited violation of very low

safety significance (Green). The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination

Process. Findings for which the significance determination process does not apply may be

Green or be assigned a severity level after NRC management review. 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.

Identification and Resolution of Problems

The inspectors reviewed approximately 400 condition reports, work orders, cause evaluations,

self-assessments and audits, operating experience evaluations, system health reports, trending

reports, metrics, and other supporting documentation to determine if problems were being

properly identified, prioritized, evaluated, and resolved.

The inspectors concluded that the licensee generally identified, evaluated, and corrected

problems according to their safety significance. The licensee generally analyzed operating

experience appropriately, performed effective self-assessments, and maintained an effective

safety conscious work environment.

The inspectors identified weaknesses in the areas of operability evaluations, thorough

evaluations, and the effectiveness of corrective actions. This was evidenced most notably by

repetitive diesel failures in 2009 and three recent cited violations. The inspectors noted that the

previous Problem Identification and Resolution inspection, documented in NRC Inspection

Report 2009007, identified weaknesses in operability evaluations and that some root causes

could have been more thorough. Therefore, the inspectors considered the weaknesses in

operability evaluations and thorough evaluations to be repetitive weaknesses. In addition,

NRC Inspection Report 2011002 documents a repetitive weakness in initiating condition reports

evidenced by multiple noncited violations. The inspectors concluded that the licensee needs to

be more effective at correcting the observed corrective action program weaknesses in

identification, operability evaluations, and thorough evaluations.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, associated with four examples of the licensees failure

to promptly identify and correct conditions adverse to quality. Specifically, the licensee

failed to identify and correct excessive setpoint drift of reactor core isolation cooling

-2- Enclosure 2

system pressure switches, the leak of oil from the service water booster pump, a

vulnerability that allowed non-quality controlled material to be installed in safety related

applications, and the cause of a failure of the high pressure coolant injection steam line

high flow instrument. The licensee entered the finding into the corrective action program

as Condition Reports 2011-07060, 2011-07105, 2011-07151, and 2011-06653.

The performance deficiency was determined to be more than minor because if left

uncorrected, the continued failure to promptly identify and correct conditions adverse to

quality could result in more risk significant equipment being inoperable, and is therefore

a finding. This finding affected the Mitigating Systems Cornerstone. Using Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, the finding was determined to have very low safety significance because the

finding: (1) was not a design or qualification issue confirmed not to result in a loss of

operability or functionality; (2) did not represent an actual loss of safety function of the

system or train; (3) did not result in the loss of one or more trains of nontechnical

specification equipment; and (4) did not screen as potentially risk significant due to a

seismic, flooding, or severe weather initiating event. The finding was determined to

have a crosscutting aspect in the area of problem identification and resolution,

associated with the corrective action program component, in that, the licensee failed to

implement a corrective action program with a low threshold for identifying issues; issues

are identified completely, accurately and in a timely manner commensurate with their

safety significance P.1(a) (Section 4OA2.5a).

Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for the failure to correct a condition adverse to quality.

Specifically, the licensee determined that an interim corrective action to prevent

recurrence was ineffective, yet it took no effective corrective action. As a result, the

licensee was vulnerable to a repetitive condition adverse to quality. The licensee

entered the issue into the corrective action program as Condition Report 2011-07152.

The finding was determined to be more than minor because the performance deficiency

could be reasonably viewed as a precursor to an event in that the interim action was not

effective as a barrier to prevent recurrence of an event. The finding is associated with

the Mitigating Systems Cornerstone. The inspectors performed a Phase 1 screening in

accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low safety

significance (Green) because the finding: (1) was not a design or qualification issue

confirmed not to result in a loss of operability or functionality; (2) did not represent an

actual loss of safety function of the system or train; (3) did not result in the loss of one or

more trains of nontechnical specification equipment; and (4) did not screen as potentially

risk significant due to a seismic, flooding, or severe weather initiating event. The

inspectors determined that this finding had a crosscutting aspect in the area of problem

identification and resolution associated with corrective actions because the licensee

failed to prioritize and thoroughly evaluate a condition report that documented an

inadequate interim corrective action to prevent recurrence P.1(c) (Section 4OA2.5d).

-3- Enclosure 2

Green. The inspectors identified a cited violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to assure that the applicable

design basis for applicable structures, systems, and components were correctly

translated into specifications, procedures, and instructions. Specifically, the licensee

failed to justify through evaluation that the diesel generator fuel oil day tanks would be

available following a tornado missile strike on the tank vents. The violation was cited

because the licensee failed to restore compliance in a reasonable time following

documentation of the issue as a noncited violation in NRC Inspection Report 2010007

(issued December 3, 2010). The licensee entered this issue into the corrective action

program as Condition Report 2011-06655.

The performance deficiency was determined to be more than minor because it was

associated with the protection against the external factors attribute of the Mitigating

Systems Cornerstone, and affected the associated cornerstone objective to ensure

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

prevent undesirable consequences, and is therefore a finding. Using Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, the finding was determined to have very low safety significance because the

finding: (1) was not a design or qualification issue confirmed not to result in a loss of

operability or functionality; (2) did not represent an actual loss of safety function of the

system or train; (3) did not result in the loss of one or more trains of nontechnical

specification equipment; and (4) did not screen as potentially risk significant due to a

seismic, flooding, or severe weather initiating event. The finding was determined to

have a crosscutting aspect in the area of human performance, associated with the

decision making component in that the licensee failed to use conservative assumptions

in decision making and adopt a requirement to demonstrate that the proposed action is

safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to

disapprove the action H.1(b) (Section 4OA2.5e).

Cornerstone: Miscellaneous

Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.73,

Licensee Event Report System, associated with the licensees failure to submit a

licensee event report within 60 days following discovery of an event meeting the

reportability criteria as specified. Specifically, a condition prohibited by technical

specifications occurred when a zurn strainer failure rendered the service water system

inoperable for longer than the action statement and would have prevented fulfillment of a

safety function. The licensee entered the finding into the corrective action program as

Condition Report 2011-06778.

The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors

determined that traditional enforcement was applicable to this issue because the NRC's

regulatory ability was affected. Specifically, the NRC relies on the licensees to identify

and report conditions or events meeting the criteria specified in regulations in order to

perform its regulatory function; and when this is not done, the regulatory function is

impacted. The inspectors determined that this finding was not suitable for evaluation

-4- Enclosure 2

using the significance determination process, and as such, was evaluated in accordance

with the NRC Enforcement Policy. The finding was a violation determined to be of very

low safety significance, was not repetitive or willful, and was entered into the corrective

action program. Therefore, this violation is being treated as a Severity Level IV noncited

violation consistent with the NRC Enforcement Policy. This finding had a crosscutting

aspect in the area of problem identification and resolution associated with the corrective

action component, in that, the licensee failed to appropriately and thoroughly evaluate

for reportability aspects all factors associated with the equipment failure P.1(c)

(Section 4OA2.5b).

Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.59,

Changes, Tests, and Experiments, associated with the failure to adequately evaluate a

change in order to ensure that it did not require prior NRC approval. Specifically, the

licensee revised a residual heat removal pump motor cable sizing calculation to a

smaller sized cable without a change evaluation. The licensee entered the issue into the

corrective action program as Condition Report 2011-01730.

The finding was determined to be more than minor because the licensee failed to

perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on

licensees to identify and report conditions or events meeting the criteria specified in

regulations in order to perform its regulatory function, and when this is not done the

regulatory function is impacted, and is therefore more than minor. Violations of

10 CFR 50.59 are considered to impede or impact the regulatory process, so they are

dispositioned using the traditional enforcement process. The enforcement manual

specifies that the severity level is determined in parallel with the Significance

Determination Process (SDP). The inspectors performed a Phase 1 screening in

accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low safety

significance (Green) because the finding: (1) was not a design or qualification issue

confirmed not to result in a loss of operability or functionality; (2) did not represent an

actual loss of safety function of the system or train; (3) did not result in the loss of one or

more trains of nontechnical specification equipment; and (4) did not screen as potentially

risk significant due to a seismic, flooding, or severe weather initiating event. Therefore,

the inspectors categorized the finding as Severity Level IV in accordance with the

enforcement manual. The finding was a violation determined to be of very low safety

significance, was not repetitive or willful, and was entered into the corrective action

program. Therefore, this violation is being treated as a noncited violation consistent with

the NRC Enforcement Policy. The inspectors determined the cause of the finding

through interviews and document reviews. This finding was determined to have a

crosscutting aspect in the area of problem identification and resolution associated with

the corrective action program in that the licensee failed to appropriately and thoroughly

evaluate all factors associated with the design change P.1(c) (Section 4OA2.5c).

B. Licensee-Identified Violations

None

-5- Enclosure 2

REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152)

The inspectors based the following conclusions on the sample of corrective action

documents that were initiated in the assessment period, which ranged from

April 11, 2009, to the end of the on-site portion of this inspection on June 24, 2011.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed documents, interviewed personnel, attended meetings, and

walked down plant equipment to determine if problems were being appropriately

identified, prioritized, evaluated, and resolved.

The inspectors verified that the licensee entered problems into the condition report

system for resolution. The inspectors reviewed the information related to problems to

ensure that the evaluations were thorough. The inspectors verified that the licensee

considered the extent of cause and extent of condition for problems as appropriate, as

well as how the licensee assessed previous occurrences. The inspectors assessed how

the licensee prioritized problems so that corrective actions were appropriate and timely.

In addition, the inspectors verified the effectiveness of corrective actions, completed or

planned, and looked for additional examples of similar problems. The inspectors also

expanded their review to the previous five years for age-related problems to determine

whether they were being effectively addressed.

In order to accomplish the above, the inspectors reviewed approximately 250 condition

reports out of approximately 20,000 that had been issued during the assessment period.

The inspectors also reviewed a sample of system health reports, self-assessments,

trending reports, metrics, selected logs, audits, operability evaluations, and results from

surveillance tests and preventive maintenance tasks. The inspectors reviewed a sample

of corrective actions closed to other corrective action documents. The inspectors

attended the licensees Condition Review Group and the Corrective Action Review

Board to observe the management of prioritizations, evaluations, and corrective actions.

The inspectors interviewed plant personnel to identify other processes that may exist

where problems may be identified and addressed outside the corrective action program.

The inspectors reviewed corrective action documents that addressed past

NRC-identified violations to ensure that the corrective action addressed the issues as

described in the inspection reports. The inspectors considered risk insights and selected

the DC Distribution System for a detailed work order and condition report review, and a

system walkdown.

At the time of the inspection, a potentially greater than green finding was identified in

NRC Inspection Report 2010006. In addition, a special inspection was ongoing due to a

-6- Enclosure 2

radiation protection event associated with a shuttle tube, as documented in NRC

Inspection Report 2011008. The inspectors excluded these issues from this inspection

due to the predecisional nature of the findings.

b. Assessments

1. Assessment - Effectiveness of Problem Identification

The inspectors concluded that the licensee identified conditions adverse to

quality and entered them into the corrective action program in accordance with

the licensees corrective action program guidance and NRC requirements.

During the inspection, the inspectors observed that the licensee identified

problems at a low threshold. However, NRC Inspection Report 2011002, Section

4OA2, documented a programmatic weakness associated with failure to initiate

condition reports. This was evidenced by multiple examples of failure to initiate

condition reports over several years with ineffective programmatic corrective

actions by the licensee.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues

The inspectors concluded that generally, the licensee effectively evaluated

problems. However, the inspectors determined that there were two indications of

weak evaluations during this assessment period. Specifically, the inspectors

identified five inadequate operability evaluations, and the inspectors identified

multiple examples of evaluations that were not thorough. The inspectors noted

that the previous Problem Identification and Resolution inspection report, NRC

Inspection Report 2009007, also documented weaknesses in operability

evaluations and that some root causes that were not thorough. Therefore, the

inspectors considered the weaknesses in operability evaluations and thorough

evaluations to be repetitive weaknesses that the licensee had not corrected.

Inadequate Operability Evaluations

In Condition Report 2011-06686, the licensee documented that springs

had been installed on both diesel generator fuel racks, which had not

been evaluated as a modification. The inspectors identified during the

inspection that the licensee had failed to include the moment arm in the

calculation of torque on the fuel rack. The licensee updated the

operability evaluation and concluded that both diesel generators were

operable because the torque applied by the spring was less than

allowable.

In Condition Report 2010-08960, the licensee determined that the control

room handswitch for RHR-MOV-27A, residual heat removal loop A

injection outboard throttle valve, was experiencing an intermittent failure.

However, the station declared the valve operable because the valve had

passed troubleshooting and post maintenance testing. The inspectors

-7- Enclosure 2

challenged the licensees operability determination because the cause

evaluation did not match the operability statement in that the cause of the

intermittent failure had not been corrected, affecting the reliability of the

valve to reposition by manipulating the handswitch. The licensee updated

the operability evaluation to include the safety function of the valve, which

only included automatic repositioning. The handswitch does not affect

the automatic repositioning; therefore, the valve was operable.

In Condition Report 2009-09486, the licensee documented a water

hammer event in the reactor coolant system. The licensee identified that

the event was a repeat of an event in 1994. However, the inspectors

identified that the licensee had failed to evaluate or act on the operability

concern raised in 1994. Specifically, General Electric recommended that

the licensee test the low pressure coolant injection check valve to ensure

that it was not damaged by the water hammer. The inspectors found that

the licensee had restarted the plant following the 2009 water hammer

without evaluating or testing the check valve. However, the valve passed

an unrelated scheduled surveillance in 2011. Therefore, the valve was

operable.

In Condition Report 2011-04689, operations personnel documented an

initial operability determination for a low oil level in a service water

booster pump. However, the inspectors identified that the licensee failed

to include the level trend and mission time for the pump in the evaluation.

The licensee determined that the pump was inoperable on April 27, 2011,

after revising the operability determination due to the inspectors

questions.

In Condition Report 2010-02213, the licensee documented the failure of a

service water zurn strainer. However, the inspectors identified that the

licensee inappropriately credited manual actions for operability. This

resulted in the licensee failing to submit an event report to the NRC, as

documented in Section 4OA2.5b of this report.

Evaluations That Were Not Thorough

The inspectors identified four examples of the licensees failure to

promptly identify and correct conditions adverse to quality that were

associated with evaluations that were not thorough. Specifically, the

licensee failed to identify and correct excessive setpoint drift of reactor

core isolation cooling system pressure switches, determine and correct

the leak path of oil from a service water booster pump, failed to identify

and correct a vulnerability that allowed non-quality controlled material to

be installed in safety related applications, and failed to identify and correct

the cause of a malfunction of a high pressure coolant injection steam line

high flow instrument. See Section 4OA2.5a of this report for more details.

-8- Enclosure 2

The inspectors identified that the licensee revised a residual heat removal

pump motor cable sizing calculation to a smaller sized cable without a

change evaluation. See Section 4OA2.5c of this report for more details.

In NRC Inspection Report 2009008, inspectors documented that the

licensee incorrectly concluded that a diesel generator lube oil piping

failure was caused by four overstress events. However, two independent

laboratories concluded that the cause was high cycle fatigue. The

licensees evaluation was not thorough, which resulted in ineffective

corrective actions and an additional failure of the diesel generator.

In NRC Inspection Report 2009005, inspectors documented a self-

revealing failure of a diesel generator due to loose fasteners on the

mechanical overspeed governor drive flange. The licensees root cause

found that personnel had failed to identify a trend of oil leaks and other

loose fasteners as a symptom of generic fastener relaxation on the

engines.

3. Assessment - Effectiveness of Corrective Action Program

The inspectors concluded that actions to correct problems were generally

effective. However, the inspectors identified multiple examples of ineffective

corrective actions, as seen below. In addition, the inspectors noted that the NRC

had documented three cited violations due to ineffective or untimely corrective

actions associated with NRC documented findings within the past two years,

including the cited violation in this report. Therefore, the inspectors considered

that the licensee had a weakness in ensuring effective corrective actions.

Condition Report 2010-05972 was initiated August 19, 2010, because

maintenance personnel had blocked open the steam exclusion barrier

door for the emergency diesel generators without taking the appropriate

compensatory measures. The licensee determined that this issue

represented a significant condition adverse to quality, and had developed

and implemented actions to prevent recurrence of this issue.

Subsequently, the inspectors identified that maintenance personnel

had again disabled a hazard barrier, the steam exclusion barrier doors

for the control room, without taking the appropriate compensatory

measures, as documented in Condition Report 2010-09639, and

Condition Report 2011-00684. The inspectors determined that this was a

recurrence of a significant condition adverse to quality because of

ineffective corrective actions.

The inspectors identified that the licensee revised a residual heat removal

pump motor cable sizing calculation to a smaller sized cable in response

to an NRC finding documented in NRC Inspection Report 2010007.

However, the licensee failed to perform a change evaluation for the

calculation change. Therefore, while the licensees actions corrected the

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compliance issue, the corrective actions were not fully effective.

See Section 4OA2.5c of this report for more details.

The inspectors identified that the licensee took no effective corrective

action after determining that an interim corrective action to prevent

recurrence was ineffective. Specifically, after the licensee identified that

the craft lacked sufficient knowledge on the Risk Release for

Maintenance process in a root cause evaluation, the licensee provided

training as corrective action to prevent recurrence. However, the licensee

identified that the training was ineffective and took no other interim

effective corrective action. See Section 4OA2.5d of this report for more

details.

The inspectors identified that the licensee failed to justify that the diesel

generator fuel oil day tanks would be available following a tornado missile

strike on the tank vents. The violation was cited because the licensee

failed to restore compliance in a reasonable time following documentation

of the issue as a noncited violation in NRC Inspection Report 2010007.

See Section 4OA2.5e of this report for more details.

In NRC Inspection Report 2010004, inspectors documented a

self-revealing finding for a breaker fire due to ineffective corrective

actions. The same breaker had a fire the previous year, but the licensee

failed to implement measurable and reasonable corrective actions.

In NRC Inspection Report 2010007, inspectors documented a failure to

correct conditions adverse to quality involving three examples of

inadequate installation and testing of safety-related batteries.

In NRC Inspection Report 2011002, inspectors documented a cited

violation for the repetitive failure to correctly assess and manage the risk

to offsite power equipment during nearby work with heavy equipment as

required by 10 CFR 50.65(a)(4).

In NRC Inspection Report 2010005, inspectors documented a cited

violation for the failure to promptly correct a licensee identified violation

involving inappropriately extending protective action recommendations

when the wind changed direction.

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.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors examined the licensee's program for reviewing industry operating

experience, including reviewing the governing procedure and self-assessments. The

inspectors reviewed a sample of industry operating experience evaluations to assess

whether the licensee had appropriately evaluated the notifications for relevance to the

facility. The inspectors also reviewed assigned actions to address the applicable

operating experience to ensure they were appropriate. The inspectors reviewed a

sample of root and apparent cause evaluations to ensure that the licensee had

appropriately included industry operating experience.

b. Assessment

The inspectors concluded that the licensee adequately evaluated industry operating

experience for relevance to the facility and appropriately entered applicable operating

experience, including causal evaluations, into the corrective action program.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of licensee self-assessments and audits to assess

whether the licensee was regularly identifying performance trends and effectively

addressing them. The inspectors sampled self-assessments and audits in several

different areas of the licensees organization.

b. Assessment

The inspectors concluded that the licensees self-assessment process was effective.

The licensee had recently taken action to revise the self-assessment process to achieve

better results. In addition, appropriate management attention was given to self-

assessments and audits. Self-assessments and audits included personnel from outside

organizations. Self-assessments and audits were determined to be critical.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors conducted individual interviews with twenty individuals. The interviewees

represented various functional organizations and included contractor, staff, and

supervisor levels. The inspectors conducted these interviews to assess whether

conditions existed that would challenge the establishment of a safety conscious work

environment.

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b. Assessment

The inspectors concluded that the licensee maintained a safety conscious work

environment. The individuals interviewed were aware of, and indicated that they were

willing to use the various ways to bring problems to managements attention without fear

of retaliation.

.5 Specific Issues Identified During This Inspection

a. Failure to Promptly Identify and Correct Conditions Adverse to Quality

Introduction. The inspectors identified a noncited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, associated with four examples of the

licensees failure to promptly identify and correct conditions adverse to quality.

Specifically, the licensee failed to identify and correct excessive setpoint drift of reactor

core isolation cooling system pressure switches, the leak of oil from the service water

booster pump, a vulnerability that allowed non-quality controlled material to be installed

in safety related applications, and the cause of a failure of the high pressure coolant

injection steam line high flow instrument.

Description. The inspectors identified four examples of a noncited violation of

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with the

licensees failure to promptly identify and correct conditions adverse to quality.

Example 1) The inspectors reviewed Condition Report 2009-01756, which had been

initiated on March 5, 2009, to document that pressure switch RCIC-PS-87D was found

out of technical specification allowed tolerance while the licensee was performing a

surveillance test of the steam supply pressure monitors for the reactor core isolation

cooling system. The licensee performed an apparent cause evaluation to determine why

the switch had gone outside of its allowed tolerance band. Through this evaluation, the

licensee determined that the mechanistic cause was set point drift. The licensee

identified the apparent cause as inadequate set point monitoring during quarterly

functional testing which allowed the set point to drift beyond the technical specification

limit. The licensee replaced the switch and calibrated the replacement switch in

accordance with the set point calculation.

The inspectors questioned the identified apparent cause. Specifically, the inspectors

noted that the calculation that had established the set point for the switch also accounted

for worse case drift. In doing this, the licensee incorporated a margin to ensure that the

switch would not be outside of the technical specification limit. As such, the inspectors

determined that the identified mechanistic cause was correct, but the identified apparent

cause was incorrect. Therefore, the corrective actions were inadequate and

subsequently, switch RCIC-PS-87D was found outside of its technical specification

allowed tolerance during another surveillance test on December 7, 2009.

The licensee initiated Condition Report 2011-07060 to capture this issue in the

corrective action program.

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The inspectors noted that the licensee has since replaced this style pressure switch in

the reactor core isolation cooling system with a switch of a different design.

Example 2) The inspectors reviewed Condition Report 2009-03602, which had been

initiated because on May 7, 2009, the licensee identified that the B service water booster

pumps inboard bearing oil level was below the level required for it to be considered

operable. The licensee classified this condition report as a Category C, broke-fix issue,

and assigned it to the operations department to address the issue of operators failing to

recognize that the level in the bearing was below the operability limit. This classification

required operations to do a fix evaluation. Based on their evaluation, operations

determined that the cause of the issue was a lack of operations personnel knowledge on

the required oil level.

Operations personnel documented that the oil had been drained and refilled one week

prior to being discovered below the operability limit (2 3/4 of an inch below the reference

mark). Prior to a post maintenance pump run, oil level was a "bubble" below the

maximum startup level (2 3/16 of an inch below the reference mark). Operations

personnel had noted that the oil level eventually leveled off near the minimum startup oil

level (2 3/8 of an inch below the reference mark) following the pump run and cool down

period. Subsequently, on May 7, 2009, the oil level was below the operability limit. The

inspectors determined that the operations department evaluation sufficiently addressed

the personnel knowledge issue, however, the cause of the oil level lowering was not

identified or corrected.

The licensee initiated Condition Report 2011-07105 to capture this issue in the

corrective action program.

Example 3) The inspectors reviewed Condition Report 2010-02123, which had been

initiated because on March 23, 2010, when planning a safety related engineering

package, the planner noted that one of the items specified for use, electrical lugs, were

not safety related. Further investigation revealed that these lugs were listed as non-

essential in the material control program; however, they were listed as safety related in

the engineering package list of materials. Through subsequent reviews of previous

packages to determine if these lugs had been installed in the plant, the planner

determined that these same lugs had been incorrectly installed in the plant in safety

related applications. Specifically, they had been installed in three service water booster

pump closing circuitries. The licensee classified this condition report as a Category C,

broke-fix issue, and assigned it to the work control group. This classification required

the work control group to do a fix evaluation. Based on their evaluation, the work control

group determined that two actions needed to be taken; 1) replace the non-safety related

materials installed in the service water booster pumps, and 2) remove the non-safety

related material from the warehouse.

During the inspectors review of this fix evaluation they noted that while the licensee had

taken action to ensure that the material could not be installed in the plant again, they had

not taken action to determine how non-safety related material had been designated for

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use in a safety related application in four safety related work orders. Therefore, the

inspectors determined that the licensee had failed to promptly identify and correct a

condition adverse to quality. The inspectors also noted that subsequently, the licensee

had identified more instances where non-safety related materials had been designated

for use in safety related applications through safety related work orders.

The licensee initiated Condition Report 2011-07151 to capture this issue in the

corrective action program.

Example 4) The inspectors reviewed Condition Report 2010-07390, which had been

initiated because on October 6, 2010, during the licensees performance of surveillance

testing of the high pressure coolant injection steam line high flow pressure instrument,

HPCI-DPIS-77, it was found to be out of its technical specification allowed tolerance.

The licensee performed an apparent cause evaluation to determine why the switch had

gone outside of its allowed tolerance band. Based on their evaluation, the licensee

determined that the apparent cause of this issue was the unavailability of spare parts

necessitated an in-field repair.

The inspectors questioned the identified apparent cause. Specifically, during their

review the inspectors noted that one month prior to the failure, HPCI-DPIS-77 had been

taken out of service to replace two internal switch assemblies. This was done as part of

the extent of condition actions resulting from the failure of a similar instrument. During

the replacement of the switches, technicians broke a mounting post for the micro

switches. Due to the unavailability of a complete spare instrument, the licensee had

determined that the only option was to perform an in-field repair (i.e., replacing internal

parts to fix the broken mounting post). An in-field repair required the technicians to

perform a full disassembly and removal of the internal mechanism of the switch. During

the alignment and calibration per station procedure, the technicians had difficulty

adjusting the switches to the correct calibration tolerance, but after several hours of

alignment and adjustment technicians were able to get the switches calibrated to the

tolerance specified in the procedure.

The inspectors determined that the licensee considered an in-field repair acceptable,

and that if done correctly, it would have corrected the condition. The inspectors

determined that the inadequate in-field repair caused the misalignment of the

mechanical components in the switch, which caused the failure to meet the surveillance

requirement. Therefore, the inspectors determined that the licensees conclusion in the

apparent cause was incorrect.

The licensee initiated Condition Report 2011-06653 to capture this issue in the

corrective action program.

These examples demonstrate the licensees failure to have a low threshold for

documenting additional issues in the corrective action program when evaluating existing

conditions.

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Analysis. The failure to promptly identify and correct conditions adverse to quality was a

performance deficiency. The performance deficiency was determined to be more than

minor because if left uncorrected, the licensees continued failure to promptly identify

and correct conditions adverse to quality could result in more risk significant equipment

being inoperable, and is therefore a finding. This finding affected the Mitigating Systems

Cornerstone. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening

and Characterization of Findings, the finding was determined to have very low safety

significance because the finding: (1) was not a design or qualification issue confirmed

not to result in a loss of operability or functionality; (2) did not represent an actual loss of

safety function of the system or train; (3) did not result in the loss of one or more trains of

nontechnical specification equipment; and (4) did not screen as potentially risk

significant due to a seismic, flooding, or severe weather initiating event. The inspectors

determined the cause of the finding through interviews and document reviews. The

finding was determined to have a crosscutting aspect in the area of problem

identification and resolution, associated with the corrective action program component,

in that, the licensee failed to implement a corrective action program with a low threshold

for identifying issues; issues are identified completely, accurately and in a timely manner

commensurate with their safety significance P.1(a).

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,

Criterion XVI, Corrective Action, requires, in part, that Measures shall be established

to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies,

deviations, defective material and equipment, and nonconformances are promptly

identified and corrected. Contrary to the above, between March 5, 2009, and

October 6, 2010, the licensee failed to promptly identify and correct conditions adverse

to quality. Because this finding is of very low safety significance and has been entered

into the corrective action program as Condition Reports 2011-07060, 2011-06653,

2011-07105, and 2011-07151, this violation is being treated as a noncited violation

consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000298/2011006-01, Failure to Promptly Identify and Correct Conditions Adverse to

Quality.

b. Failure to Report Conditions Prohibited by Technical Specifications and Safety System

Functional Failures

Introduction. The inspectors identified a Severity Level IV noncited violation of

10 CFR 50.73, Licensee Event Report System, associated with the licensees failure to

submit a licensee event report within 60 days following discovery of an event meeting

the reportability criteria as specified. Specifically, a condition prohibited by technical

specifications occurred when a zurn strainer failure rendered the service water system

inoperable for longer than the action statement and would have prevented fulfillment of a

safety function.

Description. On May 14, 2010, the licensee completed a root cause evaluation of a

component failure associated with the train A service water zurn strainer wiper arm

motor-to-gear box coupling, which had occurred on March 27, 2010, and was

documented in Condition Report 2010-02213. This failure resulted in the strainer motor

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not being able to perform its function of rotating the wiper arm for backwash, an

essential function required for Technical Specification 3.7.2, Service Water System and

Ultimate Heat Sink. The licensees evaluation concluded that the failure was due to an

inadequate design of the reduction gear to motor shaft. Through review of previous

maintenance documents and condition reports, the licensee determined that this issue

had existed since initial installation of the system.

The inspectors noted that the licensee had performed an operability evaluation at the

time of the failure and determined the equipment was operable because manual actions

could be taken to rotate the strainer for backwash functions. As such, the inspectors

noted that when licensing personnel reviewed this issue for potential reportability they

noted that this event was not reportable because the equipment was operable.

The inspectors questioned the operability position taken by the licensee. Specifically,

while the strainer essential function could be performed by way of manual actions, this

did not meet the station technical specification definition of operable:

A system, subsystem, division, component, or device shall be OPERABLE or

have OPERABILITY when it is capable of performing its specified safety

function(s), and when all necessary attendant instrumentation, controls, normal

or emergency electrical power, cooling and seal water, lubrication and other

auxiliary equipment that are required for the system, subsystem, division,

component, or device to perform its specified safety function(s) are also capable

of performing their related support function(s).

The identified condition appeared to meet the definition of operable with compensatory

measures required, as defined by station procedure EN-OP-104:

OPERABLE-COM MEAS is a PCRS Flag for Continued Operability/Functionality

based on an evaluation following an initial screening of Operable/Functional-

Judgment or Inoperable. It is a category of identifying and tracking degraded or

nonconforming conditions that represent a challenge to the

Operability/Functionality of an SSC such that additional measures have to be

taken to maintain or assure Operability/Functionality. Additional measures may

involve compensatory measures, operational restraints (i.e., startup restraints,

time limits, MODE change restrictions, and weather changes), further analysis, or

a change to the licensing bases (i.e., CLB change).

As such, the inspectors concluded that the strainer had in fact been inoperable prior to

this event, and the licensee had operated the service water system in a condition

prohibited by technical specifications. Furthermore, through reviews and discussions

with licensee personnel, the inspectors determined that prior maintenance activities

conducted by the licensee had allowed the B train of service water to be taken out of

service while the affected A train of service water was credited as operable. The

inspectors determined that these activities resulted in a condition that prevented the

service water system from performing its safety function. The licensee initiated

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Condition Report 2011-06778 to capture this issue in the stations corrective action

program.

The inspectors determined that the licensee failed to appropriately and thoroughly

evaluate for reportability aspects all factors associated with the equipment failure.

Analysis. The failure to submit a required licensee event report within 60 days after

discovery of an event or condition requiring a report to the NRC was a performance

deficiency. The inspectors reviewed this issue in accordance with NRC Inspection

Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the

inspectors determined that traditional enforcement was applicable to this issue because

the NRC's regulatory ability was affected. Specifically, the NRC relies on the licensees

to identify and report conditions or events meeting the criteria specified in regulations in

order to perform its regulatory function; and when this is not done, the regulatory

function is impacted. The inspectors determined that this finding was not suitable for

evaluation using the significance determination process, and as such, was evaluated in

accordance with the NRC Enforcement Policy. The finding was a violation determined to

be of very low safety significance, was not repetitive or willful, and was entered into the

corrective action program. Therefore, this violation is being treated as a Severity Level

IV noncited violation consistent with the NRC Enforcement Policy. The inspectors

determined the cause of the finding through interviews and document reviews. This

finding had a crosscutting aspect in the area of problem identification and resolution

associated with the corrective action component, in that, the licensee failed to

appropriately and thoroughly evaluate for reportability aspects all factors associated with

the equipment failure P.1(c).

Enforcement. Title 10 CFR 50.73(a)(1) requires, in part, that licensees shall submit a

licensee event report for any event of the type described in this paragraph within 60 days

after the discovery of the event. Title 10 CFR 50.73(a)(2)(i)(B) requires, in part, that the

licensee report any operation or condition prohibited by the plant's technical

specification, and Title 10 CFR 50.73(a)(2)(v) requires, in part, that the licensee report

any event or condition that could have prevented the fulfillment of the safety function of

structures or systems that are needed to

Shutdown the reactor and maintain it in a safe condition

Remove residual heat

Control the release of radioactive material

Mitigate the consequences of an accident

Contrary to the above, it was determined that the service water system had been

operated in a condition prohibited by technical specifications due to a design

inadequacy, and the licensee failed to correctly report this inadequacy that could have

prevented the fulfillment of its safety function during past maintenance activities. This

finding was determined to be applicable to traditional enforcement because the failure to

report conditions or events meeting the criteria specified in regulations affects the NRCs

regulatory ability. The finding was evaluated in accordance with the NRC's Enforcement

Policy. The finding was a violation of very low safety significance, was not repetitive or

- 17 - Enclosure 2

willful, and was entered into the corrective action program. This violation is being

treated as a Severity Level IV noncited violation, consistent with the NRC Enforcement

Policy: 05000298/2011006-02, Failure to Report Conditions Prohibited by Technical

Specifications and Safety System Functional Failures.

c. Failure to Perform 10 CFR 50.59 Evaluation for Design Change

Introduction. The inspectors identified a Severity Level IV noncited violation of

10 CFR 50.59, Changes, Tests, and Experiments, associated with the failure to

adequately evaluate a change in order to ensure that it did not require prior NRC

approval. Specifically, the licensee revised a residual heat removal pump motor cable

sizing calculation to a smaller sized cable without a change evaluation.

Description. During an NRC component design basis inspection, inspectors identified

that the licensee had changed residual heat removal pump motor cables from 4/0 to 2/0

power cables without adequate technical justification in the design basis calculations.

The inspection finding was documented in NRC Inspection Report 2010007 and the

licensee documented the concern in Condition Report 2010-05522. In order to resolve

the problem, the licensee performed a calculation documented in NEDC-10-075 to justify

the design change. In processing the corrective action and calculation change, the

licensee did not perform an evaluation in accordance with 10 CFR 50.59 to ensure that

the change did not require prior NRC approval. The inspectors determined that it was

not immediately clear if it would have required prior NRC approval. The licensee

entered the issue in the corrective action program as Condition Report 2011-07130.

The inspectors determined that the licensee failed to thoroughly evaluate the factors

associated with the design change.

Analysis. The inspectors determined that the failure to perform a 10 CFR 50.59

evaluation for design change calculation NEDC-10-075 was a performance deficiency.

The finding was determined to be more than minor because the licensee failed to

perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on

licensees to identify and report conditions or events meeting the criteria specified in

regulations in order to perform its regulatory function, and when this is not done the

regulatory function is impacted, and is therefore more than minor. Violations of 10 CFR

50.59 are considered to impede or impact the regulatory process, so they are