IR 05000313/2013005

IR 05000313-13-005, 05000368-13-005, on 10/01/2013 - 12/31/2013, Arkansas Nuclear One, Units 1 and 2, Integrated Inspection Report, Fire Protection and Operability Determinations and Functionality Assessments

ML14035A420
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/04/2014
From:	Greg Werner NRC/RGN-IV/DRP/RPB-D
To:	Jeremy G. Browning Entergy Operations
References
IR-13-005
Download: ML14035A420 (47)

Text

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON ary 4, 2014

SUBJECT:

ARKANSAS NUCLEAR ONE - NRC INTEGRATED INSPECTION REPORT 050003 NRC's 13/2013005 AND 05000368/2013005

Dear Mr. Browning:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One Station, Units 1 and 2. On January 16, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, 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, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Arkansas Nuclear One.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Arkansas Nuclear One.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gregory E. Werner, Acting Branch Chief Project Branch E Division of Reactor Projects Docket Nos.: 50-313, 50-368 License Nos: DRP-51; NPF-6

Enclosure:

Inspection Report 05000313/2013005 and 05000368/2013005 w/ Attachments:

1. Supplemental Information 2. Request for Information for O

REGION IV==

Docket: 05000313; 05000368 License: DPR-51; NPF-6 Report: 05000313/2013005; 05000368/2013005 Licensee: Entergy Operations Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64 West and Hwy. 333 South Russellville, Arkansas Dates: October 1 through December 31, 2013 Inspectors: B. Tindell, Senior Resident Inspector A. Fairbanks, Resident Inspector M. Young, Resident Inspector K. Clayton, Senior Operations Engineer L. Ricketson, P.E., Senior Health Physicist Approved G. Werner, Acting Branch Chief By: Chief, Project Branch E Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000313/2013005; 05000368/2013005; 10/01/2013 - 12/31/2013, Arkansas Nuclear One,

Units 1 and 2, Integrated Inspection Report; Fire Protection and Operability Determinations and Functionality Assessments.

The inspection activities described in this report were performed between October 1, 2013, and December 31, 2013, by the resident inspectors at Arkansas Nuclear One and inspectors from the NRCs Region IV office. Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red),

which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,

Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green.

Inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to hang the fluorescent light fixture above the Unit 1 motor driven emergency feedwater pump in a seismically qualified design configuration. This was not an immediate safety concern because operability was adequately demonstrated when the misconfiguration was identified and because the licensee restored the light fixture to its seismically qualified configuration on November 12, 2013. The licensee entered this issue into their corrective action program as Condition Report CR-ANO-1-2013-02830.

Inspectors concluded that the licensees failure to hang the fluorescent light fixture above the Unit 1 motor driven emergency feedwater pump in accordance with Drawing E-2060 was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating system cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Specifically, the licensee failed to ensure that, during a design basis seismic event, the light would not fall and adversely impact the safety-related pump below. Using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green)because the finding was a deficiency affecting the design or qualification of mitigating equipment, in which the equipment maintained its operability; and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event.

The finding was determined to have a cross-cutting aspect in the area of human performance, associated with resources, for the licensees failure to ensure that sufficient personnel were available for light inspections. Specifically, during the safety-related room inspections that were completed on August 27, 2013, the licensee failed to identify that the light above the motor driven emergency feedwater pump was inappropriately hung, due to the hurried nature of the inspections H.2(b) (Section 1R05).

Green.

Inspectors identified a non-cited violation of 10 CFR 50.55a(b)(5), In-Service Inspection Code Cases, for the licensees failure to implement ASME Code Case N-513-2,

Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping, Section XI, Division 1. Specifically, when a service water weld developed a leak, the licensee failed to characterize the flaw using a volumetric inspection method. The licensee corrected the condition by performing volumetric inspections of the flawed weld and then repaired the weld. The licensee entered this issue into their corrective action program as Condition Report CR-ANO-2-2013-01961.

Inspectors concluded that the licensees failure to characterize a service water weld flaw was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Specifically, the licensee failed to ensure the reliability of the service water system wasnt adversely affected by a significant weld flaw. Using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, the inspectors determined this finding was of very low safety significance (Green) because the degraded condition was not a design deficiency that affected system operability; did not represent an actual loss of function or a system; did not represent an actual loss of function of a single train or two separate trains for greater than its technical specification allowed outage time; did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant; and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event.

The finding was determined to have a cross-cutting aspect in the area of human performance, associated with resources, for the licensees failure to ensure adequate training of personnel. Specifically, personnel performing the flaw inspection were not adequately trained in the non-destructive testing requirements of the code case

H.2(b)(Section 1R15).

PLANT STATUS

Unit 1 began the period at 82.5 percent power due to degraded flow from a heater drain pump.

After repairs, operators raised power to approximately 100 percent power on October 7, 2013, and remained at full power for the rest of the inspection period.

Unit 2 began the inspection period at approximately 100 percent power. On December 9, 2013, the unit auxiliary transformer exploded. The debris caused an electrical fault on startup transformer 3. The reactor tripped and the licensee performed a natural circulation cooldown to cold shutdown using startup transformer 2 and emergency diesel generator B for electrical power. On December 22, 2013, main steam isolation valve A failed to close while the plant was in cold shutdown. The licensee remained in cold shutdown until the end of the inspection period for valve troubleshooting and repair.

REPORT DETAILS

REACTOR SAFETY

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

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On October 24, 2013, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold temperatures and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous weather season.

The inspectors selected two risk-significant systems that were required to be protected from cold temperatures:

• Units 1 and 2, quality condensate storage tank

• Unit 1, intake structure The inspectors reviewed the licensees procedures and design information to ensure the systems and components would remain functional when challenged by cold weather.

The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.

These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness to Cope with External Flooding

a. Inspection Scope

On December 4, 2013, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose two plant areas that were susceptible to flooding:

• Unit 1, intake structure

• Unit 2, intake structure The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.

These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

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

• October 15, 2013, Unit 1, emergency diesel generator B while emergency diesel generator A was inoperable for planned maintenance

• October 25, 2013, Unit 2, turbine driven emergency feedwater pump while emergency diesel generator A was inoperable for planned maintenance

• December 4, 2013, Unit 1, service water loop A while loop B was inoperable for planned maintenance

• December 19, 2013, Units 1 and 2, startup transformer 2 while startup transformers 1 and 3 were inoperable for emergent maintenance The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On October 7, 2013, the inspectors performed a complete system walk-down inspection of Unit 1 high pressure injection pump B while high pressure injection pump C was inoperable for emergent maintenance. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety:

• October 11, 2013, Unit 1, Fire Zone 38-Y, emergency feedwater pump area

• October 22, 2013, Unit 2, Fire Zone 2014-LL, high pressure safety injection and low pressure safety injection pump room, train A

• October 24, 2013, Unit 2, Fire Zone 2150-C, old core protection calculator room

• December 9, 2013, Unit 2, Fire Zone FZ-2068, transformer area

• December 19, 2013, Unit 2, Fire Zone 2200-MM, turbine building For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

Introduction.

Inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to hang the fluorescent light fixture above the Unit 1 motor driven emergency feedwater pump in a seismically qualified configuration.

Description.

During a walkdown of the Unit 1 emergency feedwater pump room on October 11, 2013, inspectors identified that the fluorescent light above the motor driven emergency feedwater pump was not suspended in accordance with Drawing E-2060, Seismic Supported Fluorescent Fixture to Concrete Ceiling, Revision 1, Sheet 47.

Specifically, the fixture located directly above the motor driven emergency feedwater pump was suspended using open S hooks and a bent eye bolt. Drawing E-2060 specified that the S hooks be closed and the eye bolts be vertically installed with a closed eye. Inspectors were concerned that the open S hooks and the bent eye bolt may have resulted in the light and chain falling and impacting the pump below, during a seismic event. The licensee documented the inspectors concern in Condition Report CR-ANO-1-2013-02830 and performed an operability determination on the pump.

Inspectors reviewed the operability determination and agreed with the conclusion that the pump remained operable. The licensee corrected the configuration of the hanging light on November 12, 2013.

Inspectors reviewed the licensees corrective actions from Condition Report CR-ANO-C-2013-00631, written in March 2013, which performed an extent of condition inspection of light fixtures in safety-related areas. The condition report included corrective action requirements to inspect and restore fluorescent light fixtures and S hooks to the correct seismic configuration, specified in Drawing E-2060, in all safety-related rooms or areas. The corrective action description contained a list of the rooms for Units 1 and 2 that needed to be inspected; including the Unit 1 emergency feedwater pump room. Inspectors noted that the corrective actions were completed August 27, 2013, and that the light in the emergency feedwater pump room should have been corrected.

The licensee told inspectors that the light in the pump room had been overlooked due to the August light inspections being hurried. Due to the oversight, the licensee completed another inspection in safety-related areas and identified additional S hooks and light fixtures that needed to be adjusted to meet their seismically qualified design. The licensee did not identify any equipment that was made inoperable due to any inadequate light fixtures.

Analysis.

Inspectors concluded that the licensees failure to hang the fluorescent light fixture above the Unit 1 motor driven emergency feedwater pump in accordance with Drawing E-2060 was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating system cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Specifically, the licensee failed to ensure that, during a design basis seismic event, the light would not fall and adversely impact the safety-related pump below. Using Manual Chapter 0609, 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of mitigating equipment, in which the equipment maintained its operability; and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event.

The finding was determined to have a cross-cutting aspect in the area of human performance, associated with resources, for the licensees failure to ensure that sufficient personnel were available for light inspections. Specifically, during the safety-related room inspections that were completed on August 27, 2013, the licensee failed to identify that the light above the motor driven emergency feedwater pump was not seismically attached, due to the hurried nature of the inspections H.2(b).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Drawing E-2060, Seismic Supported Fluorescent Fixture to Concrete Ceiling, Revision 1, is a drawing used for hanging fluorescent lighting in a seismically qualified configuration, which is an activity affecting quality. Contrary to the above, prior to October 11, 2013, the licensee failed to hang the fluorescent light fixture above the Unit 1 motor driven emergency feedwater pump in accordance with Drawing E-2060. This was not an immediate safety concern because operability was adequately demonstrated when the misconfiguration was identified and because the licensee restored the light fixture to its seismically qualified configuration on November 12, 2013. Because the finding is of very low safety significance (Green) and the issue has been entered into the corrective action program as Condition Report CR-ANO-1-2013-02830, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000313/2013005-01, Failure to Maintain Fluorescent Light Fixture Above Emergency Feedwater Pump in Seismically Qualified Configuration.

.2 Annual Inspection

a. Inspection Scope

On November 19, 2013, the inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of an announced fire drill for the Unit 2 chemistry lab and surrounding offices.

During this drill, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.

These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

On October 3, 2013, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors observed the licensees inspection of the Unit 2 containment spray pump B seal cooler and the material condition of the heat exchanger internals. Additionally, the inspectors walked down the seal cooler to observe its performance and material condition and verified that the seal cooler was correctly categorized under the Maintenance Rule and was receiving the required maintenance.

These activities constitute completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On November 6, 2013, the inspectors observed Units 1 and 2 simulator training for the operating crews. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the performance of the simulator during the training activities.

These activities constitute completion of two quarterly licensed operator requalification program samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. The inspectors observed the operators performance of the following activities:

• November 5, 2013, Unit 1, turbine-driven emergency feedwater surveillance

• November 15, 2013, Unit 2, main turbine valve stroke test

• November 20, 2013, Unit 2, containment spray A sump valve stroke test In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedures and other operations department policies.

These activities constitute completion of three quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Inspection (Units 1 and 2)

The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, Arkansas Nuclear One, Unit 2, was in the first part of the training cycle while Arkansas Nuclear One, Unit 1, was in the second part of the training cycle.

a. Inspection Scope

The inspector reviewed the results of the examinations and operating tests for both units to satisfy the annual inspection requirements.

On September 4, 2013, the licensee informed the lead inspector of the following Unit 2 results:

• 12 of 12 crews passed the simulator portion of the operating test

• 58 of 58 licensed operators passed the simulator portion of the operating test

• 58 of 58 licensed operators passed the job performance measure portion of the examination Because there were no overall failures in any of these areas, there were no required remediations performed for the Unit 2 operating tests.

On September 4, 2013, the licensee informed the lead inspector of the following Unit 1 results:

• 11 of 12 crews passed the simulator portion of the operating test

• 55 of 56 licensed operators passed the simulator portion of the operating test

• 56 of 56 licensed operators passed the job performance measure portion of the examination

• 56 of 58 licensed operators passed the written examination The individuals that failed the simulator scenario portions of the operating test were remediated, retested, and passed their retake operating tests prior to returning to shift.

The two individuals that failed the written examinations were remediated, retested, and passed their retake written examinations prior to returning to shift.

The inspector completed one inspection sample of the annual licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed four instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):

• December 3, 2013, Unit 1, instrument air compressor A tripped

• December 5, 2013, Unit 1, A3 and A4 breaker failures

• December 20, 2013, Unit 1, plant performance criteria

• December 20, 2013, Units 1 and 2, alternate ac diesel generator unavailability The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of four maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

On December 17, 2013, the inspectors observed portions of emergent work activities in the switchyard that included de-energizing startup transformers 1 and 3, which had the potential to cause an initiating event, to affect the functional capability of mitigating systems, and to impact barrier integrity.

The inspectors verified that the licensee appropriately developed and followed a work plan for these activities, including a review of the risk assessment. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

These activities constitute completion of one maintenance risk assessments and emergent work control inspection sample, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed two operability determinations that the licensee performed for degraded or nonconforming SSCs:

• October 21, 2013, Unit 2, operability determination of service water B valve weld flaw

• December 11, 2013, Unit 1, operability determination of startup transformer 1 following startup transformer 3 electrical fault The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

These activities constitute completion of two operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

Introduction.

Inspectors identified a Green non-cited violation of 10 CFR 50.55a(b)(5),

In-Service Inspection Code Cases, for the licensees failure to implement ASME Code Case N-513-2, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping, Section XI, Division 1. Specifically, when a service water weld developed a leak, the licensee failed to characterize the flaw using a volumetric inspection method.

Description.

Inspectors reviewed Condition Report CR-ANO-2-2013-01913, initiated on October 11, 2013, for water leaking out of a weld on the Unit 2 service water loop B supply to emergency control room chiller B. The leakage was indicative of a flaw in the weld. The licensee chose to apply ASME Code Case N-513-2 to temporarily allow continued operation with the flaw. The code case required volumetric inspections to characterize the flaw geometry so that it could be evaluated.

The licensee performed ultrasonic thickness measurements of the weld area, but had not been able to detect any thickness loss or flaw. However, the inspectors noted that the leak was through a linear crack, which should be able to be detected. The licensees operability evaluation assumed that the flaw was a pit, contrary to the evidence of the linear surface crack, and without subsurface flaw geometry.

The inspectors determined through interviews that the ultrasonic thickness measurements were taken on the metal adjacent to the flawed weld, with no measurements through the weld. Therefore, the licensees method of volumetric inspection would not be able to characterize a flaw in the weld material or in the boundary between the pipe and the weld.

The licensee performed the ultrasonic thickness measurements through the flawed weld on October 23, 2013, after inspectors questioned the operability evaluation. The licensee characterized the flaw and detected more degradation than was visible on the weld surface. The licensee determined that the weld was still able to perform its structural function, so there was no actual loss of system function.

The inspectors determined, through interviews, that licensee personnel had an inadequate understanding of the code case requirement to perform volumetric inspection through the plane of the flaw. As a result, in some cases, the licensee was performing inspections as close to the plane of the flaw as they could without preparing the surface to obtain the results required by the code case.

Analysis.

Inspectors concluded that the licensees failure to characterize a service water weld flaw was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Specifically, the licensee failed to ensure the reliability of the service water system wasnt adversely affected by a significant weld flaw. Using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, the inspectors determined this finding was of very low safety significance (Green) because the degraded condition was not a design deficiency that affected system operability; did not represent an actual loss of function or a system; did not represent an actual loss of function of a single train or two separate trains for greater than its technical specification allowed outage time; did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant; and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event.

The finding was determined to have a cross-cutting aspect in the area of human performance, associated with resources, for the licensees failure to ensure adequate training of personnel. Specifically, personnel performing the flaw inspection inadequately understood the code case requirements H.2(b).

Enforcement.

Title 10 CFR 50.55a(b)(5), states, in part, that licensees may apply ASME Boiler and Pressure Vessel Code cases listed in Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 16.

Regulatory Guide 1.147 listed, in part, ASME Code Case N-513-2. ASME Code Case N-513-2, states, in part, that the flaw geometry shall be characterized by volumetric inspection methods and the full pipe circumference at the flaw location shall be inspected to characterize the length and depth of all flaws in the pipe section.

Contrary to the above, from October 11, 2013, to October 23, 2013, the licensee implemented Code Case N-513-2 without characterizing the flaw by volumetrice inspection methods and without inspecting the full pipe circumference to characterize the length and depth of all flaws in the pipe section. Specifically, the licensee performed volumetric inspections of the pipe adjacent to the weld, which did not characterize the weld flaw. The licensee corrected the condition by performing volumetric inspections of the flawed weld and then repaired the weld. Because this finding is of very low safety significance (Green) and has been entered into the corrective action program as Condition Report CR-ANO-2-2013-01961, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000368/2013005-02, Inadequate Operability Evaluation Due to Failure to Characterize Weld Flaw.

1R18 Plant Modifications

a. Inspection Scope

On December 20, 2013, the inspectors reviewed a temporary modification to provide power from startup transformer 3 to Unit 2 during full power operation until the next refueling outage.

The inspectors verified that the licensee had installed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed three post-maintenance testing activities that affected risk-significant SSCs:

• October 17, 2013, Unit 1, emergency diesel generator A governor oil replacement and venting

• October 17, 2013, Unit 1, emergency diesel generator A governor local speed indicator replacement

• October 17, 2013, Unit 1, emergency diesel generator A 24-month maintenance overhaul The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of three post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the Unit 2 outage that continued through the end of the inspection period, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:

• Review of the licensees outage plan

• Monitoring of shut-down and cool-down activities

• Verification that the licensee maintained defense-in-depth during outage activities These activities constitute completion of one outage activities sample, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed seven risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

• November 5, 2013, Unit 1, turbine driven emergency feedwater pump

• November 20, 2013, Unit 2, containment spray A sump valve stroke test Other surveillance tests:

• October 29, 2013, Unit 2, low pressure safety injection pump B test

• November 4, 2013, Unit 1, borated water storage tank chemistry sample

• November 13, 2013, Unit 2, wide range containment pressure A calibration

• November 15, 2013, Unit 2, main turbine control valves, stop valves, and stop/intercept valves stroke test

• December 19, 2013, Unit 2, startup transformer 3 differential relay functional test The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of seven surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)

a. Inspection Scope

The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession number ML13262A430 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on October 9, 2013, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the Unit 1 simulator, technical support center, operations support center, and emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

.2 Training Evolution Observation

a. Inspection Scope

On November 4, 2013, the inspectors observed a Unit 2 simulator-based licensed operator requalification training that included implementation of the licensees emergency plan. The inspectors verified that the licensees protective action recommendations were appropriate. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the evaluators and entered into the corrective action program for resolution.

These activities constitute completion of one training observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

The inspectors assessed the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• The hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels

• Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions

• Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability

• Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

The inspectors verified that the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• The licensees use, when applicable, of ventilation systems as part of its engineering controls

• The licensees respiratory protection program for use, maintenance, and quality assurance of NIOSH certified equipment, and qualification and training of personnel

• The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Audits, self-assessments, and corrective action documents related to in-plant airborne radioactivity control and mitigation since the last inspection These activities constitute completion of one sample of in-plant airborne radioactivity control and mitigation as defined in Inspection Procedure 71124.03.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2012, through September 30, 2013, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for residual heat removal systems for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2012, through September 30, 2013, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for cooling water support systems for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors verified that there were no unplanned exposures and/or losses of radiological control over locked high radiation areas and very high radiation areas during the period of July 1, 2012, to September 30, 2013. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 mrem and reviewed corrective action program records. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to determine the accuracy of the reported data.

These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual

(ODCM) Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred during the period July 1, 2012, to September 30, 2013, to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to determine the accuracy of the reported data.

These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in-depth follow-up:

• On October 18, 2013, inspectors reviewed operator workarounds for Units 1 and 2.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the conditions.

• On December 9, 2013, the Unit 2 auxiliary transformer exploded.

The inspectors assessed the licensees problem identification threshold, interim cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of two annual follow-up samples, which included one operator work-around sample, as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

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

a. Inspection Scope

On December 9, 2013, the Unit 2 auxiliary transformer exploded. The debris caused an electrical fault on startup transformer 3. The Unit 2 reactor tripped due to the loss of power for the reactor coolant pumps. The licensee declared a Notification of Unusual Event due to the transformer fire and explosion. Operators performed a natural circulation cooldown to cold shutdown with startup transformer 2 and emergency diesel generator B providing power for emergency equipment.

Unit 1 lost power from startup transformer 1 when the autotransformer locked out due to the Unit 2 electrical fault. The reactor did not trip because the unit auxiliary transformer was still available. There were no other significant impacts on Unit 1.

Inspectors observed implementation of emergency and abnormal operating procedures, verified emergency action levels, verified the status of safety equipment and barriers, assessed radiological impacts, and observed command and control functions.

These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The inspector obtained the final annual examination results and telephonically exited with Mr. R. Martin, Operations Training Superintendent, on September 5, 2013. The inspector did not review any proprietary information during this inspection.

On December 12, 2013, the inspectors presented the radiation safety inspection results to Ms. S. Pyle, Manager, Regulatory Assurance, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On January 16, 2014, the inspectors presented the inspection results to Mr. J. Browning, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Browning, Site Vice President

P. Butler, Supervisor, Systems Engineering

M. Chisum, Vice President/General Manager, Plant Operations

G. Damron, Instrumentation Technician, Radiation Protection

B. Eichenberger, Manager, Corrective Action and Assurance

R. Fuller, Manager, Nuclear Oversight

C. Garbe, Supervisor, Reactor Engineering

B. Greeson, Procurement Manager, Engineering

M. Hall, Licensing Specialist

D. Hughes, Engineering Supervisor

D. James, Director, Regulatory and Performance Department

B. Lynch, Superintendent, Radiation Protection

R. Martin, Superintendent, Operations Training

D. Marvel, Manager, Radiation Protection

M. McCullah, Radiation Protection Specialist

N. Mosher, Licensing Specialist

K. Panther, Nondestructive Examination Lead

S. Pyle, Manager, Regulatory Assurance

A. Remer, Project Manager

P. Schlutermor, Boric Acid Lead

C. Simpson, Superintendent, U2 Operations Training

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000313/2013005-01 NCV Failure to Maintain Fluorescent Light Fixture Above Emergency Feedwater Pump in Seismically Qualified Configuration (Section 1R05)

05000368/2013005-02 NCV Inadequate Operability Evaluation Due to Failure to Characterize Weld Flaw (Section 1R15)