IR 05000002/2020090

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IR 05000220-090-10 and 05000410-09-010; Nine Mile Point Nuclear Station, LLC; on 10/5-22/2009; Nine Mile Point Nuclear Station, Units 1 and 2; Biennial Baseline Inspection of Identification and Resolution of Problems Report
ML093380180
Person / Time
Site: Nine Mile Point, 05000002 Exelon icon.png
Issue date: 12/04/2009
From: Powell R J
Division Reactor Projects I
To: Belcher S
Nine Mile Point
Powell R J, RI/DRP/610-337-6967
References
Download: ML093380180 (26)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 475 ALLENDALE KING OF PRUSSIA, PA December 4, 2009 Mr. Sam Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 NINE MILE POINT NUCLEAR STATION UNITS 1 AND 2 -NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000220/2009010 and 05000410/2009010

Dear Mr. Belcher:

On October 22, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, Units 1 and 2. The enclosed report documents the inspection results discussed on October 22,2009, with yourself and other members of your staff. This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems and compliance with the Commission's rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

The inspectors concluded that Constellation was generally effective in identifying, evaluating, and resolving problems.

Constellation personnel identified problems and entered them into the corrective action program at a low threshold.

Constellation prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. However, several weaknesses were noted related to the quality of evaluations.

The inspectors also concluded that, in general, Constellation adequately identified, reviewed, and applied relevant industry operating experience to Nine Mile Point Nuclear Station operations.

In addition, based on those items selected for review by the inspectors, Constellation's audits and self-assessments were thorough and probing. The report documents two NRC identified findings of very low safety significance (Green). The findings were also determined to involve violations of NRC requirements.

However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCVs, 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 0001; with copies to the Regional Administrator, Re!Jion I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC S. 2 Resident Inspector at the Nine Mile Point Nuclear Station. In addition, if you disagree with the characterization of 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 I and the NRC Resident Inspector at the Nine Mile Point Nuclear Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305,"Operatiing Reactor Assessment Program." In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://vvww.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,IRA! Raymond J. Powell, Chief Technical Support &Assessment Branch Division of Reactor Projects Docket Nos.: 50-220,50-410 license Nos.: DPR-63, NPF-69 Inspection Report 05000220/2009010 and 05000410/2009010

w/Attachment:

Supplemental Information cc Distribution via listServ Resident Inspector at the Nine Mile Point Nuclear Station. In addition, if you disagree with the characterization of 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 I and the NRC Resident Inspector at the Nine Mile Point Nuclear Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305,"Operatiing Reactor Assessment Program." In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is from the NRC Web site at httQ:llwww.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,IRAJ Raymond J. Powell, Chief Technical Support & Assessment Branch Division of Reactor Projects Docket Nos.: 50-220,50-410 License Nos.: DPR-63, NPF-69 cc w/encl: Distribution via ListServ S. Collins, RA (R10RA Mail Resource)

M. Dapas, DRA (R10RA Mail Resource)

D. Lew, DRP (R1 ORP Mail Resource)

J. Clifford, DRP (R10RP Mail Resource)

L Trocine, OEDO G. Dentel, DRP N. Perry, DRP J. Hawkins, DRP S. Sloan, DRP E. Knutson, DRP D. Dempsey, DRP K. Kolek, DRP RidsNRRPMNineMilePoint Resource RidsNrrDorlLpl1-1 Resource RoPreportsResource@nrc.gov SUNSI Review Complete:

_--:...;AA:::...:.::..R=--_ (Reviewer's Initials)

ML 09338180 DOCUMENT NAME: G:\DRP\BRANCH TSAB\lNSPECTION HEPORTS\NMP PI&R 2009\NMP200901 O.DOC After declaring this document "An Official Agency Record" it will be released to the Public. To receive a co .y 0 this document, indicate in the box:'c'= COpy without atlachmen II enclosure

'E' =COpy with atlachmen lIenciosure

'N":: No copy OFFICE: RIIDRP RIIDRP RIIDRP I I I NAME: ARosebrook/AAR GDental/GTD RPowell/RP DATE: 12/03/09 12/03/09 12/04/09 OFFICIAL RECORD COPY Docket License Report Team Approved 1 U.S. NUCLEAR REGULATORY REGION 50-220,50-410 DPR-63, NPF-69 05000220/2009010; 05000410/2009010 Nine Mile Point Nuclear Station, LLC (NMPNS) Nine Mile Point, Units 1 and 2 Oswego, NY October 5 through October 2009 Andrew Rosebrook, Senior Project Engineer, DRP D. Dempsey, Resident Inspector, DRP M. Patel, Reactor Inspector, DRS N. Lafferty, Project Engineer, DRP Raymond J. Powell, Chief Technical Support &Assessment Branch Division of Reactor Projects Enclosure

SUMMARY

OF

IR 05000220/2009010,05000410/2009010; 10/05/2009

-10/22/2009;

Nine Mile Point Nuclear Station, Units and 2; Biennial Baseline Inspection of Identification and Resolution of Problems.

The inspectors identified two findings in the areas of problem evaluation and timely and effective corrective actions. This NRC team inspection was performed by one resident inspector and three regional inspectors.

Two findings of very low safety significance (Green) were identified during this inspection and were classified as non-cited violations (NCVs). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SOP). Findings for which the SOP does not apply may be Green or assigned a severity level aftl3r NRC management review. The cutting aspect for findings is determined using IMC 0305, "Operating Reactor Assessment Program." 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 concluded that Constellation, in general, adequately identified, evaluated, and resolved problems; however, several weaknesses were noted related to the quality of evaluations.

In general, Constellation personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with the safety significance.

For most cases, Constellation screened issues for operability and reportability and performed causal analyses that considered extent of condition, generic issues, and previous occurrences.

However, weaknesses were noted in this area related to the quality of evaluations, and for one issue reviewed, the inspectors identified that the Plant Process Computer's Safety Parameter Display System (SPDS) was not appropriately scoped into the maintenance rule, resulting in an NRC identified NCV. Corrective actions taken to address the problems identified in Constellation's corrective action process were typically implemented in a timely manner. However, for one issue reviewed, Constellation did not conduct an appropriate extent of condition review for a 2008 NCV related to work hours and repeated the same performance deficiency during the 2009 Unit 1 refueling outage, resulting in an NRC identified NCV. The inspectors also concluded that, in general, Constellation adequately identified, reviewed, and applied relevant industry operating experience to Nine Mile Point Nuclear Station operations.

In addition, based on those items selected for review by the inspectors, Constellation's audits and self-assessments were thorough and probing. Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employees concerns program issues, the inspectors did not identify any concerns that site personnel were not willing to raise safety issues nor did they identify conditions that could have had a negative impact on the site's safety conscious work environment.

Cornerstone: Mitigating

Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50.65 b(2) for failure to properly scope the Safety Parameter Display System (SPDS) function of the Unit 1 Plant

Process Computer into the Maintenance Rule. As a result, a required Structure, System, and Component (SSC) was not placed in a maintenance rule a(1) status based upon unreliable system performance as required by 10 CFR 50.65. The licensee entered this issue into their corrective action program. The SPDS function of the Unit 1 Plant Process Computer not properly being scoped into the Maintenance Rule program is considered to be a performance deficiency that was reasonably within Constellation's ability to foresee and prevent. This issue is similar to a more than minor example, 7d, of IMC 0612, Appendix E, "Examples of Minor Issues." Specifically, had this issue been properly scoped into the Maintenance Rule, system performance would require that it would be placed in an a(1) status. Additionally, the finding was more than minor because it impacts the equipment performance attribute of the Mitigating Systems cornerstone and the corresponding cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors assessed this finding in accordance with IMe 0609 Attachment 4, "Phase 1 -Initial Screening and Characterization of Findings." The issue screens to very low safety significance (Green) because it did not result in the loss of a safety function, it did not result in outage time for one or more trains of a SSC to exceed its allowed Technical Specification (TS) outage times, and it is not potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors did not assign a cross-cutting issue to this finding because this was not considered to be indicative of current performance as the Maintenance Rule scoping determinations were legacy decisions. (Section 40A2.1.c.1)

Green.

The inspectors identified a Green NCV of Unit 1 TS 6.2.2.d, "Unit Staff," for not properly implementing and maintaining procedures for controlling plant staff work hours of personnel performing safety-related activities.

Constellation management authorized over 1000 overtime deviations for personnel to work greater than TS work hour limits for routine outage support activities during NMP Unit 1 outages and other reasons not permitted by TS or NMP Administrative procedures.

Constellation received a NCV in July 2008 for deficient control of staff overtime in the Operations Department and repeated the same performance deficiency in the Maintenance Department during the Unit 1 Spring 2009 refueling outage. The entered the issue into their corrective action program. The inspectors determined that failure to properly implement procedures to limit work hours for plant staff performing safety-related functions in accordance with TS 6.2.2.d was a performance deficiency that was reasonably within Constellation's ability to foresee and prevent. The finding is more than minor because, if left uncorrected, the excessive work hours could increase the likelihood of human errors during refueling outage activities and response to plant events. The finding was also similar to IMC 0612, Appendix E, "Examples Minor Issues," example 9a and would be more than minor because this inappropriate use of work hour control waivers was not an isolated incident (e.g., one or two instances).

The finding has been reviewed by NRC management in accordance with IMC 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria." The resulting increased likelihood of human error could adversely affect the station's defense-in-depth.

However, the violation was determined to be of very low significance.

because no significant events or human performance issues were directly linked to personnel fatigue as a result of the hours worked.

This issue has a cross-cutting aspect in the l:lrea of PI&R and the aspect of Corrective Action Program -Evaluation (P.1.C of IMC 0305). The licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary.

Specifically, an appropriate extent of condition review following the 2008 NCV 2008003-04 was not completed and Constellation did not identify that other departments on site (besides Operations)were vulnerable to the performance deficiencies identified and this led to Maintenance repeating many of these same performance deficiencies during the 2009 Unit 1 refueling outage. (Section 40A2.1.c.2)

.1

REPORT DETAILS

OTHER ACTIVITIES (OA)

40A2 Problem Identification and Resolution Assessment of the Corrective Action Program (CAP) Effectiveness

a. Inspection Scope

The inspection team reviewed the procedures describing Constellation's Corrective Action Program (CAP) at NMPNS Units 1 and 2. Constellation identified problems for evaluation and resolution by initiating condition reports (CRs) that were entered into the condition reporting system. The CRs were subsequently screened for operability, categorized by significance (1 (most significant)through 4 (least significant))

and assigned for further evaluation and resolution.

To assess the effectiveness of the CAP at Nine Mile Point, the inspectors reviewed performance in three primary areas: problem identification; prioritization and evaluation; and corrective action implementation.

The inspectors compared performance in these three areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," and Constellation procedure, CNG-CA-1.01-1000, "Corrective Action Program," Revision 00100. The scope of the inspectors' review for each of these areas at Nine Mile Point is described below. The inspection team evaluated the methods for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspection team interviewed plant staff and management to determine the staff's understanding of, and involvement with, the CAP. The CRs and other documents reviewed, as well as key personnel contacted, are listed in the Attachment to this report. Effectiveness of Problem Identification The inspection team reviewed CRs selected across the seven cornerstones of safety in the NRC's Reactor OverSight Process to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution.

The inspection team selected items from the engineering, maintenance, operations, physical security, radiation protection, chemistry, emergency preparedness, and oversight departments to ensure that Constellation appropriately addressed problems identified in each functional area. The inspection team selected a risk-informed sample of CRs that had been issued since the last NRC Problem, Identification and Resolution (PI&R) inspection conducted in June 2007. The inspection team considered risk insights from the NRC's and unit-specific, station's risk analyses to focus the sample selection and plant tours on risk-significant systems and components.

The corrective action review was expanded to five years for evaluation for two systems as directed by NRC Inspection Procedure (IP) 71152, "Identification and Resolution of Problems." The systems selected were the Unit 1 Containment Raw Water System and the common Radiation Monitoring Instrumentation System. Enclosure The inspection team selected items from various processes used at NMPNS to verify that they were appropriately considered for Etntry into the CAP. Specifically, the inspection team reviewed a sample of operability determinations, action requests, operationally significant issues list, trend reports, engineering system health reports, and completed surveillance tests. The inspection team also reviewed work orders for selected components to determine if station personnel entered issues identified during the performance of preventive maintenance into the CAP. The inspectors reviewed a sample of plan of the day (POD) meeting packages and meeting minutes for a sample of plant operations review committee (PORC), nuclear safety review board (NSRB), and maintenance rule expert panel meetings.

The inspectors also attended a number of POD, management review committee (MRC), and station ownership committee (SOC) meetings.

The inspectors verified that identified issues discussed at these meetings were entered into the CAP for evaluation and corrective action as appropriate.

The inspectors reviewed Emergency Preparedness (EP) Training Drill Evaluation Reports and verified that EP drill performance deficiencies identified were entered into the CAP as appropriate.

The inspectors reviewed the results of Constellation's periodic equipment and human performance trend analyses and quarterly system health reports for risk significant systems. The inspectors verified that identified trends were entered into the CAP for further evaluation and corrective action as appropriate.

The inspectors also reviewed the CAP trend code backlogs and verified thl3 applicability of trend codes entered for a sample of CAP CRs. The inspectors also verified that issues identified through internal self-assessments and audits and the operating experience (OE) program were entered into the CAP for evaluation and corrective action as appropriate.

Effectiveness of Prioritization and Evaluation of Issues The inspection team reviewed CRs to assess whether Constellation adequately evaluated and prioritized identified problems.

The issues reviewed encompassed the full range of evaluations, including root cause analyses (RCA), apparent cause evaluations (ACE), and common cause analyses (CCA). Samples of CRs that were assigned lower levels of significance were also reviewed by the inspection team to ensure they were appropriately classified.

The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution.

For significant conditions adverse to quality, the inspection team reviewed Constellation's corrective actions to preclude recurrence.

The inspectors observed four daily screeninfl meetings conducted by the SOC during the onsite weeks, and reviewed the packages for a random sample of SOC meetings conducted since the last inspection.

During these meetings, Constellation personnel reviewed new CRs for prioritization and The issues and CRs reviewed encompassed the full range of evaluations, including RCAs, ACEs, equipment apparent cause evaluations (EACE), and CCAs. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution.

The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, maintenance rule determinations, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability and reliability, reporting of issues to the NRC, and the extent of problems.

The inspectors also observed three MRC meetings during which Constellation managers reviewed completed ACEs and CCAs. Effectiveness of Corrective Actions The inspection team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems.

The inspection team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective.

The inspection team also reviewed station timeliness in implementing corrective actions and their 19ffectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors verified completion of corrective actions for a sample of CRs and work orders r.yvOs) issued since the last NRC problem identification and resolution inspection that was performed in June 2007. The inspectors considered risk insights from the station's risk analysis and ensured that the selected corrective actions were appropriately distributed across the seven cornerstones of safety and the emergency preparedness, engineering, maintenance, operations, physical security, and radiation safety functional areas. Corrective actions were verified to have been completed through documentation review and field walkdowns, when appropriate.

The inspectors also reviewed a sample of corrective actions for CRs greater than two years old. The inspectors selected these items based on risk significance, and verified appropriate interim actions were in place and that the basis for not completing the specified corrective actions was appropriately documented and well supported.

The inspectors reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Constellation's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected NCVs, event notifications, and licensee event reports to verify that Constellation personnel properly evaluated and resolved these issues. In addition, the corrective action review was expanded to five years to evaluate Constellation's actions related to the Unit 1 Containment Raw Water System and the common Radiation Monitoring Instrumentation System. b. Assessment Effectiveness of Problem Identification Constellation was generally effective in the area of problem identification.

Constellation's system had an appropriately low threshold for entering issues into the CAP and the inspectors did not identify any conditions adverse to quality which had not been entered into the CAP during their plant walkdowns and tours. Constellation's parallel problem tracking systems in the security and training departments interfaced with the primary CAP at the appropriate level. Constellation also was generally effective in identifying and addressing emerging trends and initiating corrective actions at the appropriate level. Enclosure However, the inspectors did identify one instance where Constellation was slow to identify a trend related to the Unit 1 Containment Raw Water System. A recurring issue with the Containment Spray Raw Water pump packing repeatedly overheating, resulting in unplanned unavailability of this safety-related system, was not identified until after the fifth occurrence.

The inspectors determined that due to the fact the equipment was considered inoperable during the performance of the equipment surveillance and the resulting additional unavailability due to the packing issue was not clearly identified in the CRs or operator logs, the trending program was unable to identify this trend for an extended period of time. Upon discovery, Constellation conducted an RCA and addressed the material issue. The inspectors independently evaluated the issue for potential significance per the guidance in IMC 0612, Appendix B, "Issue Screening," and Appendix E, "Examples of Minor Issues." The inspectors determined that since in each case the condition was promptly resolved and the additional unavailability was not a significant percentage of the allowed technical specification outage time, this issue was minor. Minor violations of NRC Requirements are not subject to enforcement action in accordance with the NRC Enforcement Policy. However, this minor violation and observations support the inspectors' overall assessment in the area of problem identification.

Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Constellation adequately prioritized and evaluated issues commensurate with the safety significance of the identified problem. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution.

The various CR screening and management review groups considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, amj potential impact on the safety conscious work environment (SCWE) during the conduct of reviews. There was one NRC identified Green NCV related to the failure to properly scope the SPDS function of the Plant Process Computer into the station's Maintenance Rule program. However, since this issue was not considered to be indicativo of current performance (legacy issue) it was not considered by the team for its assessment in this area. See Section 40A2.1.c.1 for additional details. However, the inspectors noted several weaknesses in this area. While making an assessment of the licensee's corrective action problem, the inspectors reviewed the documented findings over the 2 year inspection period and the results of recent inspection activities to support the team's assessment.

This review identified several significant weaknesses in Constellation's evaluation of issues. Nine Mile Point Unit 2 currently has a White Performance Indicator (PI) for the MSPI-Service Water PI. Relative to this White PI, Constellation conducted two RCAs and an ACE in response to the events that caused the equipment failures and unavailability.

These evaluations were reviewed as part of the NRC's Supplemental Inspection using NRC IP 95001. This supplemental inspection team, which formally exited their inspection in October while the PI&R team inspection was still ongoing, determined that the evaluations had significant weaknesses and the supplemental team determined Constellation had failed to identify a cause of one of the events and develop corrective actions. As a result, the Supplemental Inspection team issued a parallel White Finding to keep this issue open and a Green NCV for the inadequate cause evaluation.

In NCV 2008005-01, "Untimely Corrective Actions for Degraded Service Water Pumps," Constellation received a NCV for failing to evaluate the impact of FME being drawn into multiple running service water pumps on operability of the pumps. Several days after the event, one of the two pumps failed to start during a routine surveillance test. The team classified this as an example of failing to properly evaluate a condition adverse to quality for impact on operability. The inspectors noted a Constellation CAP procedure requirement that issues which resulted in a LER or NRC Event Notification are to have a additional layer of review (PORC). Contrary to this requirement, the team identified six CRs associated with NRC Event Notifications (4 related to SPDS/ERDS failures, 2 related to Tone Alert Radio Failures), which did not receive this additional level of review. However, the issues were reviewed and corrective actions developed and planned/completed, therefore this issue was considered to be of minor significance.

The team identified several examples of poor documentation of evaluations of issues. A number of the evaluations reviewed by the teiam did not provide enough information for the team to understand how the station reached its conclusions.

Examples include: CR 2007-005579 was generated for an untimely report to the NRC following the termination of a Notice of Unusual Event. The Constellation Nuclear Oversight organization identified this issue and recommended changes to EPIP-EPP-25, "Emergency Reclassification and Recovery," to address this issue. However, the evaluation determined that no violation of requirements had occurred and the recommendation was considered to be an enhancement.

The basis for this conclusion was not supported.

Additional information was required to demonstrate that the required NRC report had been made in a timely manner and the issue identified by the QA inspector was actually an administrative error made in the operator logs. As a result, this issue was determined to be minor. CR 2007-004584 was generated for the independent power supplies for the RCIC system. The CR identified the RCIC independent power supplies, used in N2-S0P-02, "Station Blackout (SBO) Support Procedure", Rev. 5, did not have any formal preventive maintenance (PM) activities to ensure they were capable of performing their required function during a SBO event. The CR recommended developing PMs for this equipment.

The evaluation concurred with this recommendation and developed corrective actions, but the evaluation was later revised and determined that actions were not required.

The basis for this conclusion was not supported.

Additional information, interviews, and walk downs were required to determine that the independent power supplies had been removed from the unit and placed in the warehouse during the time of the evaluation.

The power supplies had been placed under the warehouse equipment PM program (NPAP-INV-250, "In-Storage Maintenance of Stored Material,"

7) and PMs were being scheduled and performed.

As a result, this issue was determined to be minor. The team identified a vulnerability in the CAP, where items which have a time limit on them before they became reportable (Le.

8 hours
9.259259e-5 days
0.00222 hours
1.322751e-5 weeks
3.044e-6 months

of unavailability for SPDS/ERDS and

12 hours
1.388889e-4 days
0.00333 hours
1.984127e-5 weeks
4.566e-6 months

for 10 percent of EP sirens being unavailable).

Many times, the issues were identified and a CR was written with a conditional statement placed in reportability section of the CR. However, these conditional statements were not being updated to document if the issue Enclosure became reportable or not.

placed the team's concerns in their CAP and did an extent of condition review and identified several additional examples; however, no required reports were identified to have been missed. As a result, this issue is minor. The inspectors independently evaluated the problem evaluation deficiencies noted above for potential significance per the guidance in IMC 0612, Appendix B "Issue Screening," and Appendix E, "Examples of Minor Issues." Minor violations of NRC Requirements are not subject to enforcement action in accordance with the NRC Enforcement Policy. However, these minor violations and observations support the inspectors' overall assessment that Constellation's performance was adequate with weaknesses noted in the area of problem evaluation.

Effectiveness of Corrective Actions The inspectors concluded that, in general, corrective actions for identified deficiencies were typically timely and adequately implemented.

However, the team did identify a Green NCV in this area related to ineffective corrective actions for NCV 2008003-04, related to working hours during outages. As a result, during the 2009 Unit 1 refueling outage many of the same performance deficiencies were repeated.

See Section 40A2.1.c.2 for details. Additionally, the team identified instances in which corrective actions developed as part of the Operational Decision Making Checklist (ODMC), Operability Determinations (OD), and Functionality Assessments (FA) processes, were not being captured in the CAP and in some cases these actions were not completed.

For example: CR 2009-005179 identified a degraded bus tie breaker for Bus 17A and 17B. The associated FA recommended conducting bi-weekly megger tests as a compensatory action. The inspectors discovered that this action had not been completed.

However, when Constellation conducted the megger test (CR 2009-005489), the results showed the breaker was operable.

As a result, this issue was considered to be minor. The inspectors discovered that an ODMC recommendation to establish a preventive maintenance activity to open and inspect the Unit 1 feedwater flow control valve pneumatic operator was developed following the receipt of several system alarms in May 2009. This recommendation was never captured or formally evaluated in the CAP and the same piece of equipment subsequently stuck out of position resulting in a level transient and a manual scram of Unit 1 on October 5, 2009. However, based on the information the licensee had available at the timE!, even if this recommendation had been reviewed and adopted, the maintenance activity would not have been scheduled until the next refueling outage. Therefore, the recommendation would not have reasonably prevented the October 5 transient.

As a result, this issue is considered to be minor. The inspectors independently evaluated the corrective action deficiencies noted above for potential significance per the guidance in IMC 0612, Appendix B, "Issue Screening," and Appendix E, "Examples of Minor Issues." Minor violations of NRC Requirements are not subject to enforcement action in accordance with the NRC Enforcement Policy. However, these minor violations and observations support the inspectors' overall assessment.

c. Findings

Failure to properly scope the SPDS function of the Plant Process Computer into the Maintenance Rule.

Introduction:

The inspectors identified a Green NCV of 10 CFR 50.65 b(2) for failure to properly scope the Safety Parameter Display System (SPDS) function of the Unit 1 Plant Process Computer into the Maintenance Rule. As a result, this SSC was not placed in a maintenance rule a(1) status based upon unreliable system performance as required by 10 CFR 50.65.

Description:

The inspectors observed that in 2009, there had been four 10 CFR 50.72 required

8 hour
9.259259e-5 days
0.00222 hours
1.322751e-5 weeks
3.044e-6 months

event notifications made to the NRC for "a significant loss of emergency assessment capability," due to the ERDS/SPDS functions of the Plant Process Computer being unavailable for greater than

8 hours
9.259259e-5 days
0.00222 hours
1.322751e-5 weeks
3.044e-6 months

. Three of these event notifications were for Unit 1 and one was for Unit 2. When the inspectors evaluated the CRs for these failures, they discovered that this function was deemed to not be in the scope of the maintenance rule for Unit 1, while it was scoped into the maintenance rule for Unit 2. 10 CFR 50.65 b(2) requires that non-safety-related SSCs that are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures are required to be scoped into the maintenance rule. NRC Regulatory Guide 1.160 section 1.1.2 states, "SSCs which are necessary to mitigate accidents and transients and to use the Emergency Operating Procedures (EOPs) although they may not directly address the accident or transient or be explicitly mentioned in the EOPs are in scope." Constellation stated that the reason Unit 2 was in scope was because SPDS points were identified as the primary indications for several key plant parameters by Unit 2 procedures.

Constellation stated that this WEIS not the case for Unit 1. The inspectors reviewed procedure N1-S0P**29.1, "EOP Key Parameter Indications," Rev. 1, and confirmed than SPDS is identified as an alternate indication for EOP key parameter indication.

The inspectors also idl3ntified that procedure N1-S0P-42, "Loss of Annunicators," directs the operators to use SPDS to monitor plant parameters and that the loss of the Plant Process Computer was an escalation factor for two Emergency Action Levels (EALs) (Loss of Indication/Alarm/Communication Capability 7.3.3 Alert and 7.3.4. Site Area Emergency).

The inspectors also identified that EOP 5, "Secondary Containment Control," Rev. 14, has two details which specifically reference plant process computer points which are used to make decisions within EOP-5. EOP-5 details'S' and 'W' identify computer points in the four ECCS corner rooms as indication that water levels are above maximum safe levels. Procedure step SC-10 directs the operators to enter EOP-8 and blowdown the reactor coolant system if maximum safe levels for the same parameter are exceeded in two or more areas due to flooding from a primary system. Procedure step SC-6 directs operators to shut down the reactor per procedure OP-43C if maximum safe levels for the same parameter are exceeded in two or more areas due to flooding from a non primary plant system. Procedure step SC-3 directs the operators to dewater the affected compartment.

The Unit 1 Plant Computer has been identified as having reliability issues due to obsolescence and difficulty in obtaining spare and replacement components.

This unreliability was clearly demonstrated by the three 10 CFR 50.72

8 hour
9.259259e-5 days
0.00222 hours
1.322751e-5 weeks
3.044e-6 months

event notifications for a significant loss of emergency assessment capability for the ERDS/SPDS functions for greater than

8 hours
9.259259e-5 days
0.00222 hours
1.322751e-5 weeks
3.044e-6 months

. The Plant Computer is in a red condition in the System Health Report and an upgrade project is scheduled for 2011. Enclosure If the Plant Process Computer were properly scoped into the Maintenance Rule, it would be considered an a(1) system. In June 2006, EOP 5, Rev. 13, was issued. This revision added these computer points to the EOP details'S' and 'W'; therefore, Constellation had a reasonable opportunity to scope the function into the maintenance rule at that time. Constellation entered this issue into their CAP (CR 2009-006913).

Analysis:

The failure to properly scope the Unit 1 SPDS function of the Plant Process Computer into the Maintenance Rule program is considered to be a performance deficiency that was reasonably within Consteillation's ability to foresee and prevent. This issue is similar to a more than minor example, 7d, of IMC 0612, Appendix E, "Examples of Minor Issues." Specifically, had this issue been properly scoped into the Maintenance Rule, system performance would require that it would be placed in an a(1) status. Additionally, the finding was more than minor because it impacts the equipment performance attribute of the Mitigating Systems cornerstone and the corresponding cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (Le., core damage). The inspectors assessed this finding in accordance with IMC 0609 Attachment 4, "Phase 1 -Initial Screening and Characterization of Findings." The issue screens to very low safety significance (Green) because it did not result in the loss of a safety function, it did not result in outage time for one or more trains of a SSC to exceed its allowed TS outage times, and it is not potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors did not assign a cross-cutting issue to this finding because this was not considered to be indicative of current performance as the Maintenance Rule scoping determinations were legacy deciSions and the EOP revision was not recent enough to be considered a current performance issue.

Enforcement:

10 CFR 50.65 a(1) requires, in part, that SSC performance shall be monitored against licensee established goals to provide reasonable assurance these SSCs are capable of performing their intendeid safety functions.

10 CFR 50.65 b(2) requires, in part, that non-safety-related SSCs that are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures, are required to be scoped into the maintenance rule. NRC Regulatory Guide 1.160 section 1.1.2 states "SSC's which are necessary to mitigate accidents and transients and to use the EOPs although they may not directly address the accident or transient or be explicitly mentioned in the EOPs are in scope." Contrary to the above, from July 10, 1996 (the date the 10 CFR 50.65 became effective)to the present, Constellation did not scope the Unit 1 Plant Process Computer SPDS function into their Maintenance Rule program as required by 10 CFR 50.65 b(2). Since this finding is of very low safety significance and has been entered into Constellation's CAP (CR 2009-006913), this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000220/2009010-01, Failure to Properly Scope the SPDS function ofthe Plant Process Computer into the Maintenance Rule)

(2) Deficient Control of Plant Staff Overtime
Introduction:

The inspectors identified a Green NCV of Unit 1 TS 6.2.2.d, "Unit Staff," for not properly implementing and maintaining procedures for controlling plant staff work hours of personnel performing safety-related activities.

Constellation management authorized over 1000 overtime deviations for personnel to work greater than TS work hour limits for routine outage support activities during NMP Unit 1 outages and other reasons not permitted by TS or NMP Administrative procedures.

Constellation received an NCV in July 2008 for deficient control of staff overtime in the Operations Department and repeated the same performance deficiency in the Maintenance Department during the Unit 1 Spring 2009 refueling outage.

Description:

NRC Inspection Report 05000220/2008003

& 05000410/2008003 issued on July 28, 2008, documented two NCVs (NeV's 2008003-04 and 2008003-05)related to the failure to properly control the use of overtime and overtime deviations.

The corrective actions for NCV 2008003-04 were narrowly focused to only address the performance deficiencies identified in the Operations Department.

Nine Mile Point Unit 1 TS 6.2.2.d and Unit 2 TS 5.2.2.e require, in part, that overtime for staff performing safety-related functions to be limited. These TSs were developed to meet commitments made by the station is response to NRC GL 132-12, "Nuclear Power Plant Staff Working Hours," dated June 15, 1982. Specifically, Unit 1 TS 6.2.2.d stated, in part, that administrative procedures shall be developed to control the use of overtime and routine deviations from this guidance shall not be authorized.

GAP-FFD-02, "Control of Working Hours," Rev. 19, was the procedure by NMP to meet this requirement.

GAP-FFD-02, Section 5.1 and 5.2 address work hour limits. Section 5.1 B.1 identifies work hour limits of GL 82-12 and section B.2 states, "Work in Excess of these limits shall NOT be routinely authorized." Section 5.2 discusses exceeding work hour limits and gives examples of conditions which would warrant overtime deviations.

These included:

  • to respond to an LCO,
  • to complete work activities where it is safer to complete than secure,
  • to complete work on a problem immediately affecting nuclear or industrial safety,
  • absenteeism,
  • weather related extensions of work period, and
  • to complete work affecting critical path during a shutdown.

The basis of the NMP TSs and NMP procedures is NRC GL 82-12, "Nuclear Power Plant Staff Working Hours," dated June 15, 1982. Regarding overtime deviations, GL 82-12 states, "Recognizing that very unusual circumstances may arise requiring deviation from the above guidelines, such deviation shall be authorized by the plant manager or his deputy, or higher levels of management.

The paramount consideration in such authorization shall be that significant reductions in the effectiveness of operating personnel would be highly unlikely." While reviewing the approved overtime deviations for 2009, the inspectors identified that during the Spring 2009 Unit 1 refueling outage, there was a heavy reliance upon overtime deviations for scheduled maintenance activities.

During the first 9 days of the outage, 596 deviations for the

72 hours
8.333333e-4 days
0.02 hours
1.190476e-4 weeks
2.7396e-5 months

in 7 days limit were granted. The majority of these deviations were authorized for Maintenance Department personnel.

While these authorizations were, for the most part, granted prior to working the excessive hours as required by procedure, the majority were authorized for reasons not permitted by the procedure or consistent with GL 82-12 guidance.

This included scheduled overtime for entire maintenance crews for the purposes of schedule compliance, planned outage activities such as containment isolation valve leak rate testing testing, motor operated valve work, outage support, attending meetings, shift coverage, and other reasons which Enclosure would not constitute "very unusual circumstances" or match the examples described in GAP-FFD-02.

As such these deviations would be prohibited by NMP procedures and therefore the Unit 1 TSs. The inspectors also noted that in many cases, groups of up to 39 personnel were authorized deviations for a common reason. The inspectors determined that Constellation had misinterpreted the guidance in GL 82-12 and in Unit 2 TS 5.2.2.e, "Unit Staff," such that they believed that deviations were permitted for entire work groups during an outage. However, the GL 82-12 guidance and the Unit 2 TS 5.2.2.e permit overtime to be considered for an entire work group during outages to work up to the limits of GL 82-12 (

16 hours
1.851852e-4 days
0.00444 hours
2.645503e-5 weeks
6.088e-6 months

in a

24 hour
2.777778e-4 days
0.00667 hours
3.968254e-5 weeks
9.132e-6 months

period;

24 hours
2.777778e-4 days
0.00667 hours
3.968254e-5 weeks
9.132e-6 months

in

48 hour
5.555556e-4 days
0.0133 hours
7.936508e-5 weeks
1.8264e-5 months

period and

72 hours
8.333333e-4 days
0.02 hours
1.190476e-4 weeks
2.7396e-5 months

in a week). Overtime deviations from the GL 82-12 limits are discussed in the following paragraph of both TS 5.2.2.e and GL 82-12 and would only be on an individual basis for "very unusual circumstances." As such blanket authorizations are not authorized by the NMP procedure and are not permitted by the GL 82-12 guidance.

This same performance deficiency had been identified in NCV 2008-003-04.

Since deviations were being granted for large groups, each individual may not have been directly evaluated and monitored for fitness for duty due to fatigue and the intent of the deviation provision of GL 82-12 and TS 5.2.2.e was not being met. Per NMP TS, "Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by a specified corporate officer or a designee to ensure that excessive hours have not been assigned." This review required by NMP TS does not appear to have been effective in identifying this increasing trend of reliance on overtime deviations; that reasons for granting deviations were not in accordance with station procedures, GL 82-12 guidelines, or TS; and that the granting of overtime deviations for a group of operators is not consistent with the guidance of GL 82-12 or station procedures.

Constellation entered this issue into their CAP (CR 2009-006988).

Many of the programmatic changes to implement the new NRC Fatigue Rule (10 CFR 26 Subpart I, "Managing Fatigue")

which became effective on October 1, 2009, also address the performance deficiencies identified.

Analysis:

The inspectors determined that failure to properly implement procedures to limit work-hours for plant staff performing safety-related functions in accordance with TS 6.2.2.d, was a performance deficiency that was reasonably within Constellation's ability to foresee and prevent. The finding is more than minor because, if left uncorrected, the excessive work hours could increase the likelihood of human errors during refueling outage activities and response to plant events. The finding was also similar to IMC 0612, Appendix E, "Examples Minor Issues," example 9a and would be more than minor because this inappropriate use of work hour control waiver was not an isolated incident (e.g. one or two instances).

The finding has been reviewed by NRC ' management in accordance with IMC 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria." The resulting increased likelihood of human error could adversely affect the station's defense-in-depth.

However, the violation was determined to be of very low significance, because no significant events or human performance issues were directly linked to personnel fatigue as a result of the hours worked. This issue has a cross-cutting aspect in the area of PI&R and the aspect of Corrective Action Program -Evaluation (P.1.C of IMC 0305). The licensee did not thoroughly

.2 evaluate problems such that the resolutions

address causes and extent of conditions, as necessary.

Specifically, an appropriate extent of condition review following the 2008 NCV was not completed and Constellation did not identify that other departments on site (besides Operations)were vulnerable to the performance deficiencies identified.

This led to Maintenance repeating many of these same performance deficiencies during the 2009 Unit 1 refueling outage.

Enforcement:

Nine Mile Point Unit 1 Technical specifications 6.2.2.d, "Unit Staff," required procedures be established, implemented, and maintained covering the control of plant staff overtime, to limit the hours worked by staff performing safety-related functions, and specified, in part, routine deviations from the guidelines is not authorized.

GAP-FFD-02, "Control of Working Hours," Rev. 19, was the procedure developed by Constellation to meet the TS requirement.

Rev. 19, section 5.1 B.1, identifies work hour limits of GL 82-12 and section B.2 states "Work in Excess of these limits shall NOT be routinely authorized." SElction 5.2 discusses exceeding work hour limits and gives examples of conditions whicll would warrant deviations.

Contrary to the above, in 2009, particularly during the Spring 2009 Unit 1 RFO, a significant number of overtime deviations (596 though the first 9 days of the outage) were requested and approved for reasons not permitted by GAP-FFD-02 guidance.

The majority of these deviations occurred in the Maintenance Department and were approved in advance for scheduled activities and outage support. These deviations were routinely approved for entire groups of up to 39 people. The majority of these individuals worked more than

72 hours
8.333333e-4 days
0.02 hours
1.190476e-4 weeks
2.7396e-5 months

during a 7 period. These would be considered routine deviations, which are not authorized by station procedures or TSs. Many of these workers performed safety-related work and none of these workers were restricted "from performing safety-related activities.

Because this violation was of very low safety significance, and it was entered into Constellation's corrective action program (CR 2009-006988), this violation is being treated as an NCV, consistent with section VI.A.1 of the NRC Enforcement Policy. (NCV 05000220/2009010-02, Deficient Control of Plant Staff Overtime.)

Assessment of the Use of Operating Experience (OE)

a. Inspection Scope

The inspectors selected a sample of industry OE issues to confirm that Constellation evaluated the OE information for applicability to Nine Mile Point and took appropriate actions when warranted.

The inspectors reviewed OE documents to verify that Constellation appropriately considered the underlying problems associated with the issues for resolution via their CAP. The inspectors also observed plant activities to determine if industry OE was considered during the performance of routine and infrequently performed activities.

A list of the documents reviewed is included in the Attachment.

b. Assessment The inspectors determined that Constellation appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues. The inspectors assessed that, in general, the use of OE was effective.

The inspectors observed Constellation demonstrating effective use of OE in pre-job briefs, routine management meetings, and determined that Constellation effectively utilized OE during development of the Maintenance Rule a(1) Enclosure

.4 16 action plans, RCAs, and ACEs reviewed.

The inspectors independently verified that a sample of industry OE and NRC generic communications had been enter into their CAP, evaluated, and corrective actions developed as needed. OE was appropriately applied and lessons learned were communicated and incorporated into plant operations.

c. Findings

No findings of significance were identified . . 3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, Nuclear Oversight organization audits and assessments, and assessments performed by independent organizations.

These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether CAs were initiated to address identified deficiencies.

The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and identified observations made during the inspection.

A list of documents reviewed is included in the Attachment to this report. b. Assessment The inspectors concluded that self-assessments, audits, and other internal Constellation assessments were generally critical, probing, thorough, and effective in identifying issues. The inspectors observed that these audits and self-assessments were completed in a methodical manner by personnel knowledgeable in the subject. The audits and self-assessments were completed to a sufficient depth to identify issues that were entered into the CAP for evaluation.

In general, corrective actions associated with the identified issues were implemented commensurate with their safety significance.

c. Findings

No findings of significance were identified . Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors reviewed the SCWE at Nine Mile Point through conduct of the following activities: During interviews with staff personnel, the inspectors questioned individuals regarding:

willingness to raise safety concerns, knowledge of the avenues available for raising safety concerns, the effectiveness of actions taken by management to foster a SCWE at the site, and knowledge of individuals who had experienced a negative reaction for raising a safety concern. The inspectors reviewed implementation of the site employee concerns program (ECP). The inspectors compared the number and type of issues documented in the Nine Mile Point ECP between June 2007 to October 2009 to the number and type of Enclosure 17 issues documented as Nine Mile Point NRC allegations for that same period. The inspectors reviewed the site procedure for conducting ECP investigations and reviewed a sample of ECP files to assess the program's effectiveness at addressing potential safety issues. The inspectors reviewed the results of site nuclear safety culture surveys performed since the last inspection.

b. Assessment Based on interviews, observations of plant activities, and reviews of the CAP and the ECP, the inspectors determined that, in general, site personnel were willing to identify and raise safety issues. All persons interviewed demonstrated an adequate knowledge of the avenues available for raising safety concerns including CAP and ECP. In addition, comparisons of Nine Mile Point ECP files to NRC allegation information did not identify any impediments to the free flow of information at Nine Mile Point. The inspectors determined that the results of the nuclear safety culture surveys provided Constellation insights into the safety culture of the site workforce.

c. Findings

No findings of significance were identified.

40A6 Meetings.

Including Exit On October 22,2009, the inspectors presented the inspection results to Mr. Sam Belcher, Site Vice President, Nine Mile Point, and other members of his Constellation staff. The inspectors confirmed that proprietary information was reviewed by inspectors and returned to the licensee during the course of the inspection, and the content of this report includes no proprietary information.

A IT ACHMENT:

=SUPPLEMENTAL

INFORMATION=

I

A-I SUPPLEMENTAL

KEY POINTS OF

Licensee personnel

S. Belcher, Site Vice President
J. Kaminski, Director Emergency

Preparedness

B. Shanahan, Electrical

-I&C Engineer

D. Flood, Principal

Engineer

D. Wolniak, Director, Performance

Improvement

K. VanSpeybroeck, Operations
J. Dean, Director Nuclear Oversight
M. Shanbhag, Licensing
M. McCrobie, Maintenance
K. Johnson, Engineering
S. McCarthy, Maintenance
K. Daniels, Performance

Improvement

L Cole, Performance

Improvement

M. Bullis, Performance

Improvement

C. Fischer, Maintenance

Rule Engineer LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed

05000220/2009010-01

NCV Failure to Properly Scope the SPDS Function of the Plant Process Computer Into the Maintenance

Rule (Section 40A2.1.c.1)050002202009010-02

NCV Deficient

Control of Plant Staff Overtime (Section 40A2.1.c.2)

LIST OF DOCUMENTS

REVIEWED Section 40A2: Identification

and Resolution

of Problems Audits and Self-Assessments

CAP-09-01-N

Corrective

Action Program EPP-07-01-N

Emergency

Preparedness

Program 2008-3rd Qtr -Maintenance

Qtrly Performance

Report 2008-2nd Qtr -Maintenance

Qtrly Performance

Report FASA 2009-000046

Condition

Reports (CRs) *2009-005276

  • 2009-005489
  • 2009-006543
  • 2009-006556
  • 2009-006557
  • 2009-006572
  • 2009-006913
  • 2009-006914
  • 2009-006960
  • 2009-006986
  • 2009-006988
  • 2009-006989
  • 2009-006991

1996-000016

1996-002427

1996-002758

1996-003366

1997-001097

1998-003063

2001-001552

2002-005002

2004-004136

2004-004432

2004-004776

2005-000019

2005-001212

2005-002007

2005-002663

2005-002714

2005-002908

2005-002935

2005-004309

2005-004309

2005-004554

2005-004554

2005-0051

2006-000303

2006-003377

2006-005877

2006-005883

2007-000449

2007-001460

2007 -001764 2007 -002364 2007 -003532 2007 -003636 2007 -003763 2007 -003792 2007-003947

2007-004092

2007-004192

2007 -004198 2007 -004205 2007 -004224 2007 -004299 2007-004311

2007-004317

2007-004359

2007 -004417 2007 -004541 2007 -004584 2007-004584

2007-004846

2007-005306

2007-005475

2007-005475

2007-005579

2007 -005599 2007 -005624 2007 -005624 2007 -005687 2007-006024

2007-006226

2007-006371

2007-006769

2007-006769

2007-007017

2007-007809

2008-000310

2008-000332

2008-000425

2008-000554

2008-000563

2008-000651

2008-000731

2008-000953

2008-001114

2008-001546

2008-001569

2008-001569

2008-001653

2008-001696

2008-002121

2008-002166

2008-002405

2008-002473

2008-002473

2008-002976

2008-003003

2008-003234

2008-003446

2008-003484

2008-003688

2008-003705

2008-003708

2008-003708

2008-003708

2008-003879

2008-004021

2008-004256

2008-004422

2008-004569

2008-004612

2008-004806

2008-005028

2008-005105

2008-005720

2008-005745

2008-005745

2008-005779

2008-007131

2008-007375

2008-007915

2008-007915

2008-007916

2008-007977

2008-007986

2008-007994

2008-008012

2008-008016

2008-008029

2008-008094

2008-008490

2008-008492

2008-008492

2008-009116

2008-009219

2009-000080

2009-000121

2009-000230

2009-000457

2009-000548

2009-000785

2009-000791

2009-000814

2009-000892

2009-002465

2009-000903

2009-002498

2009-000942

2009-002647

2009-000950

2009-002698

2009-001169

2009-003084

2009-001169

2009-003180

2009-001336

2009-003218

2009-001337

2009-003218

2009-001337

2009-003683

2009-001433

2009-003884

2009-001433

2009-004022

2009-001494

2009-004022

2009-001494

2009-004263

2009-001875

2009-004263

2009-002161

2009-004482

2009-002193

2009-004537

2009-002211

2009-002238

  • NRC Identified

During Inspection

CNG-CA-1.01-1000, "Corrective

Action Program," Rev. N1-CTP-V200, "Sump Inspections," Rev. N1-0DP-PRO-0302, "EOP Technical

Basis," Rev. N1-0P-42,"Process

ComputerISPDS," Rev. N1-ST-Q6A, "Containment

Spray System Lube 111 Quarterly

Operability

Test," Rev. N2-CTP-GEN-@200, "Floor and Equipment

Drain Sump Inspections," Rev. CNG-CA-1.01-1001, "Management

Review Committee," Rev. CNG-OP-1.01-1001,"Operational

Decision Making," Rev. EOP 5, "Secondary

Containment

Control," Revs. 13 and EPIP-EPP-20, "Emergency

Notifications," Rev. EPIP-EPP-25, "Emergency

Reclassification

and Recovery," Rev. EPMP-EPP-01

,"Emergency

Plan," Rev. GAP-FFD-02, "Control of Working Hours," Rev. N1-S0P-29.1, "EOP Key Parameter

Indications," Rev. N1-S0P-42, "Loss of Annunicators," Rev. N2-0P-31 "RHR System" Rev. N2-0SP-RHS-M001,"RHS

Vent Valves V155, V166, and V180," Rev. N2-S0P-02, "Station Blackout Support Procedure," Hev. N2-WPM-Q@001, "Sump Inspections," Rev. NPAP-INV-250, "In-Storage

Maintenance

of Stored Material," Rev. Completed

Surveillances

N2-0SP-CSL-Q@002 (WO -08-04964-00)

N2-0SP-RHS-Q@005 (WO-08-05431-00)

N2-0SP-RHS-Q@006 (WO-08-07090-00)

Licensee Event Reports 220-2008001, "Loss of Offsite Power Due to an Equipment

Malfunction" 220-2008002, "Manual Reactor Scram due to Loss of Reactor Pressure Control" 220-2008003, "Power Supplies for Drywell Pressure Indication

not Qualified

for Required Accident Operating

Duration" 220-2009001, "Failure to Implement

Required Technical

Specification

Actions Associated

With a Failed Surveillance

Test" 220-2009002, "High Pressure Coolant Injection

System Initiation

following

a Manual Turbine Trip Due to High Turbine Bearing Vibrations" 410-2007 -901, "Invalid Primary Containment

Isolation

System Actuation" 410-2008-901, "Invalid Actuation

of Group 5 and Group 10 Primary Containment

Valves During Surveillance

Testing" Licensee Event Notifications

to the NRC (ENs) EN 43652 EN 44206 EN 44923 EN 43673 EN 44387 EN 44982 EN 43710 EN 44491 EN 45031 EN 43855 EN 44598 EN 45157 EN 43923 EN 44686 EN 45284 EN 43990 EN 44747 EN 45323 EN 44114 EN 44827 Non-Cited

Violations

2007003-01

Failure to conduct adequate testing res.ults in two inoperable

IRM channels during reactor start up 2007003-02

Procedure

noncompliance

resulted in failure to establish

Primary Containment

Integrity

prior to Reactor Startup 2007004-01

Inadequate

CCP system venting procure results in loss of main CCP pumps 2007004-02 Inadequate procedure

for a design change results in an inadvertent

discharge

of C02 suppression

system 2007005-01

Inadequate

RCIC Room Temperature

Channel Checks 2007005-02

Loss of Shutdown Cooling due to inadequate

maintenance

planning 2008002-01

Failure to correctly

perform procedure

cause inadvertent

isolation

of RCIC steam supply 2008003-01

Failure to meet TS oversight

requirements

2008003-02

Untimely corrective

actions for IA corrosion

results in Rx Feedwater

valve malfunction

2008003-03

Failure to appropriately

evaluate accelerated

aging effects on J-10 relays 2008003-04

Failure to control operations

staff overtime 2008003-05

Repetitive

improper authorization

and Ewaluation

of overtime deviations

2008004-01

Incorrect

risk assessment

for RCIC unavailability

2008004-02

Inadequate

maintenance

practice result in a plant transient

2008005-01

Untimely corrective

actions for degraded service water pumps 2008007-01

Failure to perform a technical

evaluation

or restore a non conformance

to the original design requirement

2008008-01

Inadequate

design control of Unit 1 600V MCC control circuit voltage drop Calculations

2008008-02

Inadequate

design control regarding

adequacy of safety bus allowable

degraded voltage relay reset point and Impact on offsite power 2009002-01

Inadequate

maintenance

instructions

results in RHR voiding 2009002-02

Inadequate

procedure

for MSIV troubleshooting

2009002-03

Failure to properly perform SLC surveillance

2009003-01

Failure to follow start up procedure

for second stage reheaters

leads to turbine trip. 2009003-02

SLIV NOV for operator failing to obtain SRO permission

prior to changing reactor power 2009006-01

Failure to implement

fire brigade training program procedure

Miscellaneous

CFR 26 Subpart I, "Managing

Fatigue" 10 CFR 50.65, "Requirements

for Monitoring

the Effl9ctiveness

of Maintenance

at Nuclear Power Plants" 10 CFR 50.72, "Immediate

Notification

Requirements

for Operating

Nuclear Power Reactors" 10 CFR 50.73, "Licensee

Event Reporting

System" ACR 09-02557, Action Request for Unexpected

Annunciator

when FCV 13 taken to Manual AI-2007-7798

Calculation

2081171-C-001, "Evaluation

of RHR System Suction Void," Rev. 0 Nine Mile Point ENS Communicator's

Logs for 9/19/07 Nine Mile Point Key Performance Indicators for

August 2009 Nine Mile Point Technical

Specification

Amendment

SER for Change #1 dated 01 October, 1975 Nine Mile Point Unit 1 and 2 Technical

Specifications

NRC Annual Assessment

and Mid Cycle Performance

Assessment

letters for 2007-2009

NRC GL 82-12, "Nuclear Power Plant Staff Working Hours," dated June 15, 1982 NRC Regulatory

Guide 1.160, "Monitoring

the Effectiveness

of Maintenance

at Nuclear Power Plants" NUMARC 93-01, "Industry

Guideline

for Monitoring

the Effectiveness

of Maintenance

at Nuclear Power Plants," Rev. 2 NUREG-1022, "Event Reporting

Guidelines:

CFR 50.72 and 50.73," Rev. 2 Statements

of Consideration

for 10 CFR 50.65 Federal Register, Volume 56, No. 132 July 10, 1991 Attachment

LIST OF ACRONYMS ACE ADAMS CAP CCAs

CFR CR EACE

EAL ECCS ECP EDG EOP EP FA FASA GL IMC IN HPCI LCO LO LOP/LOCA MRC NCV

NMP

NRC NSRB 00 ODMC OE PARS PI&R

POD PORC QA RCE RCIC

RHR SCWE SOP SOC SPDS SRO SRV SSC ST SW TS UFSAR WO apparent cause evaluation

Agency-wide

Documents

Access and Management

System corrective

action program common cause analyses Code of Federal Regulations

Condition

Report equipment

apparent cause evaluation

emergency

action level emergency

core cooling system employee concerns program emergency

diesel generator

emergency

operating

procedures

emergency

preparedness

functionality

assessment

focused area self assessment

Generic Letter Inspection

Manual Chapter I nformation

Notice High Pressure Coolant Injection

limiting condition

for operation

lube oil loss of offsite power/loss

of coolant accident management

review committee

non-cited

violation

Nine Mile Point Nuclear Regulatory

Commission

Nuclear Safety Review Board operability

determination

operational

decision making checklist

operating

experience

publicly available

records system problem identification

and resolution

plan of the day Plant Operations

Review Committee

Quality Assurance

root cause evaluation

reactor core isolation

cooling residual heat removal safety conscious

work environment

significance

determination

process station ownership

committee

Safety Parameter

Display System senior reactor operator safety relief valve structures, systems and components

surveillance

test service water technical

specification

Updated Final Safety Analysis Report work orders Attachment