IR 05000002/2020090
| ML093380180 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, University of Michigan  |
| 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 | |
| IR-09-010 | |
| 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of unavailability for SPDS/ERDS and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 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 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> event notifications for a significant loss of emergency assessment capability for the ERDS/SPDS functions for greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period; 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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
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
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
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
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