IR 05000445/2013003

IR 05000445-13-003, 05000446-13-003 on 3/28-6/26/2013; Comanche Peak Nuclear Power Plant, Units 1 and 2 Integrated Resident and Regional Report; Operability Evaluations, Problem Identification and Resolution, Event Followup

ML13211A459
Person / Time
Site:	Comanche Peak
Issue date:	07/30/2013
From:	Webb Patricia Walker NRC/RGN-IV/DRP/RPB-A
To:	Flores R Luminant Generation Co
Walker W
References
IR-13-003
Download: ML13211A459 (49)

Text

July 30, 2013

Rafael Flores, Senior Vice President and Chief Nuclear Officer Luminant Generation Company, LLC Comanche Peak Nuclear Power Plant P.O. Box 1002 Glen Rose, TX 76043 Subject: COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2013003 AND 05000446/2013003

Dear Mr. Flores:

On June 26, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2, facility. The enclosed inspection report documents the inspection results which were discussed on July 10, 2013, with Mr. K. Peters, Site Vice President, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Two NRC-identified findings and one self-revealing finding of very low safety significance (Green) were identified during this inspection. Two of these findings were determined to involve 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 these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2.

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 Comanche Peak Nuclear Power Plant, Units 1 and 2.

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION IV

1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Wayne C. Walker, Chief Project Branch A Division of Reactor Projects

Docket Nos.: 05000445; 05000446 License Nos.: NPF-87; NPF-89

Enclosure:

Inspection Report 05000445/2013003 and 05000446/2013003 w/Attachments: 1. Supplemental Information 2. Request for Information for the O

REGION IV==

Docket:

50-445, 50-446 License:

NPF-87, NPF-89 Report:

05000445/2013003 and 05000446/2013003 Licensee:

Luminant Generation Company LLC Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2 Location:

FM-56, Glen Rose, Texas Dates:

March 28 through June 26, 2013 Inspectors:

J. Kramer, Senior Resident Inspector B. Tindell, Resident Inspector C. Alldredge, Health Physicist I. Anchondo, Senior Reactor Inspector L. Carson II, Senior Health Physicist K. Hoffman, Nuclear Reactor Regulation B. Parks, Reactor Inspector M. Williams, Reactor Inspector Approved By:

Wayne Walker, Chief, Project Branch A Division of Reactor Projects

- 2 -

SUMMARY OF FINDINGS

IR 05000445/2013003, 05000446/2013003; 3/28-6/26/2013; Comanche Peak Nuclear Power

Plant, Units 1 and 2 Integrated Resident and Regional Report; Operability Evaluations, Problem Identification and Resolution, Event Followup.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Two Green non-cited violations and one Green finding were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the failure to follow an auxiliary feedwater system operating procedure. As a result, a water hammer occurred on the condensate storage tank makeup reject line. The licensee entered the finding into the corrective action program as Condition Report CR-2012-012539.

The finding was more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective, in that, it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, it resulted in a system water hammer. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not cause a reactor trip and the loss of mitigation equipment. The finding had a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure that personnel were adequately trained to perform the activity H.2(b)

(Section 4OA2.3).

Green.

The inspectors reviewed a self-revealing finding for the licensees failure to appropriately plan and control work activities during the installation of an air regulator in the heater drain system. As a result, the fitting that connected the air regulator to an adjacent in-line air filter broke and caused a plant transient and an automatic reactor trip. The licensee entered the finding in the corrective action program as Condition Report CR-2012-012183.

The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective in that it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available. The finding had a human performance cross-cutting aspect associated with work control in that the licensee failed to appropriately plan the work activity H.3(a) (Section 4OA3).

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of the licensee to have documented instructions of a type appropriate to the circumstances for testing the main steam safety valves. Specifically, the procedure for testing the main steam safety valves did not provide direction to declare the valves inoperable when applying pressure to the lifting device. As a result, the licensee failed to declare the main steam safety valves inoperable during testing. The licensee entered the finding in the corrective action program as Condition Report CR-2013-002947.

The finding was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure did not provide guidance to declare a main steam safety valve inoperable with the test rig installed. Using Inspection Manual Chapter 0609,

Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned (Section 1R15).

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at approximately 100 percent power. On March 30, 2013, the operators shut down Unit 1 to begin a scheduled refueling outage. On April 21, 2013, the outage ended when the main generator output breakers were closed and Unit 1 was placed on the grid. On April 24, 2013, the unit returned to approximately 100 percent power and operated at that power level for the remainder of the inspection period.

Unit 2 began the inspection period at approximately 100 percent power. On May 18, 2013, operators reduced power to approximately 70 percent power for turbine valve testing. The unit returned to approximately 100 percent power the next day and operated at that power level for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R04 Equipment Alignments

.1 Partial Equipment Walkdowns

a. Inspection Scope

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

• April 9, 2013, Unit 1, diesel generator 1-02 and train B 6.9 kV electrical bus when diesel generator 1-01 was unavailable for maintenance

• April 19, 2013, Unit 2, containment spray system inside containment following a refueling outage

• June 19, 2013, Unit 2, diesel generator 2-02 when diesel generator 2-01 was unavailable for testing The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors focused on discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Final Safety Analysis Report, technical specification requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

.2 Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of the Unit 1 turbine driven auxiliary feedwater system to verify the functional capability of the system. The inspectors selected this system because it was considered both safety-significant and risk-significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line-ups, system pressure and temperature indications, component labeling, component lubrication, hangers and supports, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the systems function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one complete system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Fire Inspection Tours (71111.05Q)

a. Inspection Scope

The inspectors conducted fire protection walkdowns in the following risk-significant plant areas:

• April 9, 2013, fire zone WB104a, service water intake structure

• April 16, 2013, fire area 1CA, Unit 1 containment

• May 16, 2013, fire zone 2SC, turbine driven auxiliary feedwater pump 2-01 room

• May 16, 2013, fire zone 2SB5, motor driven auxiliary feedwater pump 2-01 room

• May 16, 2013, fire zone 2SB6, motor driven auxiliary feedwater pump 2-02 room

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants individual plant examination of external events or their potential to affect equipment that could initiate or mitigate a plant transient. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use, that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits, and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.

These activities constitute completion of five quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors performed visual underground cable inspections of the following vaults:

• May 23, 2013, underground vault E2A1

• May 23, 2013, underground vault E2A2

• May 23, 2013, underground vault E2A3

• May 23, 2013, underground vault E2A4

The inspectors verified the adequacy of flood control measures. The inspectors reviewed the Final Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one bunker/manhole inspection sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed licensee programs, verified performance against industry standards, and reviewed critical operating parameters and maintenance records for the Unit 1 train A diesel generator jacket water to service water heat exchanger and the Unit 2 train B diesel generator jacket water to service water heat exchanger. The inspectors verified the licensee properly utilized biofouling controls; the licensees heat exchanger inspections adequately assessed the state of cleanliness of the tubes; and the heat exchanger was correctly categorized under 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.

These activities constitute completion of two heat sink inspection samples as defined in Inspection Procedure 71111.07-05.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

Completion of Sections

.1 through.5, below, constitute completion of one inservice

inspection activities sample as defined in Inspection Procedure 71111.08-05.

.1 Inspection Activities Other Than Steam Generator Tube Inspection, Pressurized Water

Reactor Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control (71111.08-02.01)

a. Inspection Scope

The inspectors observed eight nondestructive examination activities and reviewed five nondestructive examination activities that included four types of examinations. The licensee did not identify any relevant indications accepted for continued service during the nondestructive examinations.

The inspectors directly observed the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Residual Heat Removal Pipe to Elbow Weld TBX-1-4101-9 Ultrasonic Test Reactor Coolant System Mechanical Snubber TBX-1-4503 Visual (VT-3)

Safety Injection Pipe Hanger CP1-SSISSMR-05 TBX-1-4103-MR5 Visual (VT-3)

Safety Injection Spring Support SI-1-089-007-C4IS TBX-1-4103-H6 Visual (VT-3)

Safety Injection Spring Support SI-1-089-007-C4IS TBX-1-4103-H6 Dye Penetrant Test Chemical Volume Control Horizontal Letdown Heat Exchanger Heat-to-Flange TBX-2-1104-1 Ultrasonic Test Reactor Coolant System Hot Leg Nozzle DM Weld Nozzle to Safe-end/Safe-end to Pipe TBX-1-4200-1 Ultrasonic Test SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Coolant System Hot Leg Nozzle DM Weld Nozzle to Safe-end/Safe-end to Pipe TBX-1-4300-1 Ultrasonic Test

The inspectors reviewed records for the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Chemical Volume Control Manual Gate Valve 1-HV-8402A Weld No. FW-20 Radiograph Test Chemical Volume Control CS-1-074 Pipe Segment Weld No. TUX-23-2 Radiograph Test Residual Heat Removal Pipe to Elbow Weld TBX-1-4401-1 Ultrasonic Test Reactor Coolant System Hot Leg Nozzle DM Weld Nozzle to Safe-end/Safe-end to Pipe TBX-1-4100-1 Ultrasonic Test Reactor Coolant System Hot Leg Nozzle DM Weld Nozzle to Safe-end/Safe-end to Pipe TBX-1-4400-1 Ultrasonic Test

During the review and observation of each examination, the inspectors verified that activities were performed in accordance with the American Society of Mechanical Engineers Code requirements and applicable procedures. The inspectors also verified the qualifications of all nondestructive examination technicians performing the inspections were current.

The inspectors observed portions of two of the following welding activities on pressure retaining risk significant systems:

SYSTEM WELD IDENTIFICATION WELD TYPE Chemical Volume Control Manual Gate Valve 1-HV-8402A Weld No. FW-20 Gas Tungsten Arc Welding (GTAW)

Chemical Volume Control CS-1-074 Pipe Segment Weld No. TUX-23-2 Gas Tungsten Arc Welding (GTAW)

The inspectors verified that the welding procedure specifications and the welders had been properly qualified in accordance with American Society of Mechanical Engineers Code,Section IX, requirements. The inspectors also verified that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications. Specific documents reviewed during this inspection are listed in the attachment.

These actions constitute completion of the requirements for Section 02.01.

b. Findings

No findings were identified.

.2 Vessel Upper Head Penetration Inspection Activities (71111.08-02.02)

a. Inspection Scope

The licensee performed a visual inspection per procedure, Reactor Vessel Closure Head Visual Examination Plan, Revision 4. During refueling outages when a bare metal visual inspection is not required per American Society of Mechanical Engineers Code Case N-729-1, a less detailed general visual assessment is performed. The inspectors reviewed the results of the licensees visual assessment and verified that there was no evidence of boric acid challenging the structural integrity of the reactor head components and attachments.

These actions constitute completion of the requirements for Section 02.02.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control Inspection Activities (71111.08-02.03)

a. Inspection Scope

The inspectors evaluated the implementation of the licensees boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walkdown as specified in Procedure STA-737, Boric Acid Detection and Evaluation, Revision 6. The inspectors verified that the visual inspections emphasized locations where boric acid leaks could cause degradation of safety-significant components, and that engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors confirmed that corrective actions taken were consistent with the American Society of Mechanical Engineers Code, and 10 CFR 50, Appendix B requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These actions constitute completion of the requirements for Section 02.03.

b. Findings

No findings were identified.

.4 Steam Generator Tube Inspection Activities (71111.08-02.04)

a. Inspection Scope

The inspectors reviewed the steam generator tube eddy current test examination scope and expansion criteria and verified that it met technical specification requirements, electric power research institute guidelines, and commitments made to the NRC. The inspectors also verified that the eddy current test inspection scope included areas of degradations that were known to represent potential eddy current test challenges such as the top of tube sheet, tube support plates, and U-bends. The inspectors confirmed that no repairs were required at the time of the inspection. The scope of the licensees eddy current test examinations included:

• 50 percent bobbin coil testing

• 50 percent Row 1-3 U Bend +Point testing

• 20 percent Top of tube sheet Hot Leg +Point testing

• 50 percent +Point of Dings/Dents > equal to 5 volts testing

• 100 percent Peripheral Tubes (Top of Tube Sheet) +Point

• 100 percent TRA signals from PSI (23 tubes)

No tube degradation mechanisms were identified during refueling outage RF-16.

The inspectors observed portions of the eddy current testing being performed and verified that:

(1) the appropriate probes were used for identifying the expected types of degradation,

(2) calibration requirements were adhered, and

(3) probe travel speed was in accordance with procedural requirements. The inspectors performed a review of the site-specific qualifications for the techniques being used, and verified that eddy current test data analyses were adequately performed per electric power research institute and site specific guidelines. The inspectors compared the inspection results to the previous outage operational assessment to assess the licensees prediction capabilities with no issues identified. The licensee performed foreign object search and retrieval inspections on top of the tubesheet of all four steam generators. The licensee identified four objects that were left in their respective steam generator and an evaluation was performed to assess the object being left in place. The inspectors reviewed the evaluation and the images of the objects with no issues identified. The licensee made the administrative decision to preventively stabilize and plug a tube in steam generator 4 located in row 13, column 17 adjacent to one of the loose parts that could not be retrieved. The loose part was observed resting between the tube and a stay rod.

Finally, the inspectors review selected eddy current test data and verified that the analytical techniques used were adequate.

These actions constitute completion of the requirements for Section 02.04.

b. Findings

No findings were identified.

.5 Identification and Resolution of Problems (71111.08-02.05)

a. Inspection scope

The inspectors reviewed 17 condition reports associated with inservice inspection activities, and determined that the corrective actions taken were appropriate. The inspectors concluded that the licensee has an appropriate threshold for entering inservice inspection issues into the corrective action program, and has procedures that direct a root cause evaluation when necessary. The licensee also has an effective program for applying inservice inspection industry operating experience. Specific documents reviewed during this inspection are listed in the attachment.

These actions constitute completion of the requirements of Section 02.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Inspection of Licensed Operator Requalification Program

a. Inspection Scope

On May 21, 2013, the inspectors observed a crew of licensed operators in the plants simulator during requalification training. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies These activities constitute completion of one quarterly inspection of licensed operator requalification program sample as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity. The inspectors assessed the operators adherence to plant procedures and other operations department policies. The inspectors observed the operators performance of the following activities:

• April 10, 2013, Unit 1, reactor coolant system reduced inventory operations

• April 17, 2013, Unit 1, reactor coolant system vacuum fill

• April 20, 2013, Unit 1, reactor startup

• April 21, 2013, Unit 1, sync to the grid and power ascension These activities constitute completion of one quarterly observation of licensed-operator performance sample as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the alternate power diesel generators. The inspectors reviewed events where ineffective equipment maintenance had resulted in failures and independently verified the licensees actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

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

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)

The inspectors verified appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization.

These activities constituted completion of one maintenance effectiveness sample as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

• April 9, 2013, spent fuel pool cooling system defense-in-depth following Unit 1 full core offload to the spent fuel pools

• May 8, 2013, Unit 2, diesel generator 2-02 out of service for planned maintenance activities

• June 17, 2013, Units 1 and 2, XST1 transformer out of service for planned maintenance activities The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensees probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• CR-2012-011088, Unit 2, station service water pump motor breaker failed to close during outage

• CR-2013-000553, Units 1 and 2, effects of containment pressure on hydrogen detectors, radiation monitors, and storage boxes

• CR-2013-002947, Units 1 and 2, main steam safety valve testing

• CR-2013-004441, Unit 1, emergency core cooling system sump gasket not rated for maximum sump temperature

• CR-2013-004645, Unit 1, residual heat removal pumps discharge to refueling water storage tank valve, 1-8717, hard to operate The inspectors selected these operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Final Safety Analysis Report to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five operability evaluation inspection samples as defined in Inspection Procedure 71111.15-05.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to have documented instructions of a type appropriate to the circumstances for testing the main steam safety valves. Specifically, the procedure for testing the main steam safety valves did not provide direction to declare the valves inoperable when the applying pressure to the lifting device.

Description.

On March 25, 2013, the inspectors observed main steam safety valve testing on Unit 1. The licensee installed a lifting device on the valves and applied air pressure to an air motor to lift the valves and determine the lift setpoint. The inspectors discussed the testing with the unit supervisor and determined that the supervisor was not entering the technical specification action statement for an inoperable main steam safety valve when the air motor was attached and lifting the valve. The supervisor indicated that neither the procedure nor the work week schedule required the valve to be inoperable when being tested. Based on the inspectors questioning, the unit supervisor entered the technical specification statement during each of the main steam safety valve tests. The supervisor initiated Condition Report CR-2013-002947 to document the inspectors concern about the testing.

The inspectors discussed the valve testing with engineering. The inspectors determined when the test rig was installed, the actual system pressure required to cause a main steam safety valve to lift would decrease as air pressure to the air motor was increased. Ultimately during the test, the safety would actually lift at normal operating pressure and not at the technical specification required lift setpoint. When the test rig was removed, the main steam safety valve lift setpoint would return to the pre-test value. Engineering agreed with the inspectors concern that the valves were inoperable when being tested. The licensee planned to revise Procedure MSM-S0-8702, Main Steam Safety Valve Testing, Revision 4 to include statements about operability when testing the valves.

The inspectors discussed the finding with the licensee and determined that the inadequate procedure was not representative of current licensee performance.

Analysis.

The licensees failure to have documented instructions of a type appropriate to the circumstances for testing the main steam safety valves was a performance deficiency. The finding was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure did not provide guidance to declare a main steam safety valve inoperable with the test rig installed.

Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned.

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances.

Procedure MSM-S0-8702, Main Steam Safety Valve Testing, Revision 4, provided instructions, precautions, limitations, and notes for the testing of the main steam safety valves. Contrary to the above, on March 25, 2013, the licensee performed an activity affecting quality using documented instructions of a type not appropriate to the circumstances. Specifically, Procedure MSM-S0-8702 did not contain adequate instructions for declaring equipment inoperable and providing instructions to isolate the test rig during a transient. As a result, operations did not declare the main steam safety valves inoperable during testing until prompted by the inspectors. Because the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2013-002947, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy:

NCV 05000445/2013002-01; 05000446/2013002-01, Inadequate Procedure for Testing the Main Steam Safety Valves.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

• April 21, 2013, Unit 1, low power physics testing following reactor refueling

• May 9, 2013, Unit 2, diesel generator 2-02 testing following cylinder head replacement

• May 30, 2013, Unit 1, safety injection accumulator 1-04 injection valve 1-8808D testing plan following torqueing

• June 17, 2013, Unit 2, transformer XST1 testing following maintenance The inspectors selected these activities based upon the structure, system, or components ability to affect risk. The inspectors evaluated the activities to ensure the testing was adequate for the maintenance performed, the acceptance criteria were clear, and the test ensured equipment operational readiness.

The inspectors evaluated the activities against technical specifications, the Final Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them into the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four post-maintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Unit 1 refueling outage, conducted March 30, 2013, through April 21, 2013, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. During the refueling outage, the inspectors observed portions of the shutdown and cooldown of the reactor and monitored licensee controls over the outage activities listed below:

• Configuration management, including maintenance of defense-in-depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service.

• Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing.

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error.

• Status and configuration of electrical systems to ensure that technical specifications and outage safety plan requirements were met, and controls over switchyard activities.

• Monitoring of decay heat removal processes, systems, and components.

• Verification that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system.

• Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.

• Controls over activities that could affect reactivity.

• Refueling activities including fuel handling.

• Startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the containment to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing.

• Licensee identification and resolution of problems related to refueling outage activities.

• Licensees management of fatigue.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one refueling and other outage activities inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Final Safety Analysis Report, procedure requirements, technical specifications, and corrective action documents to ensure that the surveillance activities listed below demonstrated that the systems, structures, and components tested were capable of performing their intended safety functions.

Pump or Valve Inservice Test

• May 16, 2013, Unit 2, turbine driven auxiliary feedwater pump testing in accordance with Procedure OPT-206B, AFW System Surveillance Test, Revision 21 Containment Isolation Valve Test

• May 31, 2013, Unit 1, containment isolation valve testing in accordance with Procedure OPT-503A, Containment Isolation Valves ASME Testing, Revision 14 Reactor Coolant System Leakage Detection Surveillance Testing

• April 25, 2013, Unit 1, water inventory balance in accordance with Procedure OPT-303, Reactor Coolant System Water Inventory, Revision 13 Routine Surveillance Testing

• April 16, 2013, Unit 1, emergency core cooling system sump inspection in accordance with Procedure OPT-306, Containment Sump Inspection, Revision 7

• June 19, 2013, Unit 2, diesel generator testing in accordance with Procedure OPT 214B, Diesel Generator Operability Testing, Revision 16 The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper and lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME code requirements

• Updating of performance indicator data

• Reference setting data

• Annunciators and alarms setpoints Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five surveillance testing inspection samples (one pump or valve inservice test, one containment isolation valve test sample, one reactor coolant system leakage detection surveillance test sample, and two routine surveillance testing samples) as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

On June 12, 2013, the inspectors evaluated the conduct of licensee emergency drills to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and the emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also compared any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program.

These activities constituted completion of one drill and/or training evolution sample as defined in Inspection Procedure 71114.06-05.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS0 1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

This area was inspected to:

(1) review and assess licensees performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures,

(2) verify the licensee is properly identifying and reporting occupational radiation safety cornerstone performance indicators, and

(3) identify those performance deficiencies that were reportable as a performance indicator and which may have represented a substantial potential for overexposure of the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:

• Performance indicator events and associated documentation reported by the licensee in the occupational radiation safety cornerstone

• 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

• Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to radiation protection work requirements

• Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.01-05.

b. Findings

No findings were identified.

2RS0 3 In-plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

This area was inspected to verify in-plant airborne concentrations are being controlled consistent with ALARA principles and the use of respiratory protection devices on-site does not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed licensee personnel, performed walkdowns of various portions of the plant, and reviewed the following items:

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

• The licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health certified equipment, qualification and training of personnel, and user performance

• The licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions, status of self-contained breathing apparatus 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

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one sample as defined in Inspection Procedure 71124.03-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the first quarter 2013 performance indicators for any obvious inconsistencies prior to its public release in accordance with NRC Inspection Manual Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for Units 1 and 2 for the period from the second quarter 2012 through the first quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, definitions and guidance were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, and NRC integrated inspection reports to validate the accuracy of the submittals. The inspectors also reviewed the licensees condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of two safety system functional failures samples as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the third quarter 2012 through the first quarter 2013. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 rem/hr) and very high radiation area non-conformances.

The inspectors reviewed radiological, controlled area exit transactions greater than 100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas.

These activities constitute completion of one occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the third quarter 2012 through the first quarter 2013. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed the licensees corrective action program records and selected individual annual or special reports to identify potential occurrences, such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.

These activities constitute completion of one radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities, so these reviews did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

The inspectors performed a review of Condition Report CR-2011-009966 from the licensees corrective action program. The inspectors reviewed documents and interviewed personnel to determine if the licensee completely and accurately identified problems in a timely manner commensurate with its significance, evaluated and dispositioned operability issues, considered the extent of condition, prioritized the problem commensurate with its safety significance, and completed corrective actions in a timely manner commensurate with the safety significance of the issue.

These activities constitute completion of one in-depth problem identification and resolution samples as defined in Inspection Procedure 71152-05.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to follow an auxiliary feedwater system operating procedure. As a result, a water hammer occurred on the condensate storage tank makeup reject line.

Description.

The inspectors reviewed Condition Report CR-2011-009966, which documented a water hammer on the Unit 1 condensate storage tank makeup reject line.

The inspectors noted that the only action from the condition report was for an engineer to inspect the line for damage.

The condensate storage tank makeup reject line provides water to and from the hotwell to the tank. Therefore, if the line broke, it could flood safety-related equipment and cause a loss of condenser vacuum. While no damage was identified following the water hammer, the inspectors were concerned that there was a potential for a larger water hammer in the future that could break the line.

The inspectors reviewed Procedure SOP-304A, Auxiliary Feedwater System, Revision 17, the procedure being used when the water hammer occurred. The procedure contained a note about the potential for a water hammer. Step 5.5.6.E directed the operator to slowly pressurize the makeup reject header manually by slightly opening condensate storage tank 1-01 discharge valve1-HV-2484. The inspectors interviewed the operators involved in the evolution and determined that they did not follow this step because a water hammer occurred when the valve was later fully opened electronically.

The inspectors discussed the results of the inspection with the licensee. The licensee agreed with the inspectors that the operator did not follow the procedure. The licensee initiated Condition Report CR-2012-012539 to address the inspectors observations and to identify further corrective actions. The inspectors concluded that, without inspector added value, human performance errors that led to the water hammer event would not have been identified.

The inspectors discussed the cause of the event with the licensee. The inspectors determined that the operator performing the evolution was inadequately trained to perform the activity.

Analysis.

The licensees failure to follow procedure when pressurizing the condensate makeup rejects line and causing a water hammer was a performance deficiency. The finding was more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective, in that, it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, the performance deficiency resulted in a system water hammer. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment. The finding had a human performance cross-cutting aspect associated with resources, in that, licensee personnel failed to ensure that personnel were adequately trained to perform the activity H.2(b).

Enforcement.

Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Revision 2, Appendix A, Item 3.l, requires, in part, instructions for filling the auxiliary feedwater system. Procedure SOP-304A, Auxiliary Feedwater System, Revision 17, Step 5.5.6.E, stated, in part, to slowly pressurize the makeup/reject header manually by slightly opening 1-HV-2484, condensate storage tank 1-01 discharge valve.

Contrary to the above, on September 11, 2011, the licensee failed to implement Procedure SOP-304A for the auxiliary feedwater system. Specifically, the licensee failed to slowly pressurize the makeup/reject header. As a result, a water hammer occurred when the valve was electrically opened. The licensee corrected the condition by clarifying the procedure. Since the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2012-012539, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000445/2013003-02, Failure to Follow Procedure Results in Water Hammer.

.4 Operator Workarounds

a. Inspection Scope

The inspectors reviewed the Units 1 and 2 cumulative effects of operator workarounds and burdens to determine the reliability, availability, and potential for incorrect operation of systems or components. The inspectors verified the ability of operators to respond in a correct and timely manner to plant transients and accidents, and if the licensee has identified and implemented appropriate corrective actions associated with operator workarounds.

These activities constitute completion of one operator workarounds sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Event Followup

The activities documented below constitute completion of one event followup sample as defined in Inspection Procedure 71153.

(Closed) Licensee Event Report 05000446/2012-002-00, Unit 2 Automatic Reactor Trip due to Low Steam Generator Water Level

a. Inspection Scope

The licensee event report documented a low steam generator water level and Unit 2 reactor trip event. The inspectors performed a review of the event. The inspectors examined maintenance work orders, replacement item evaluations, written procedures, condition reports, and the licensees root cause analysis.

b. Findings

Introduction.

The inspectors reviewed a self-revealing Green finding for the licensees failure to appropriately plan and control work activities during the installation of an air regulator in the heater drain system. As a result, the fitting that connected the air regulator to an adjacent in-line air filter broke and caused a plant transient and an automatic reactor trip.

Description.

On November 17, 2012, with Unit 2 operating at 100 percent power, the fitting between the air regulator for heater drain pump discharge valve 2-LV-2592 and its adjacent in-line air filter failed. The loss of air pressure caused the heater drain pump discharge valve to close, which resulted in a total loss of heater drain flow and a reactor trip on low steam generator water level.

The licensees root cause analysis concluded that the work order did not provide adequate instruction on how to install the regulator. The regulator was a replacement component and was not compatible with the mounting bracket of the original regulator.

This incompatibility was not addressed in the worker order. Subsequently, maintenance personnel installed the regulator and only supported it with the fittings and not a mounting bracket.

The inspectors determined that form MG-10-1, Work Order Pre-Work Review Form, was a self-imposed licensee standard that required that work order steps address the work and that procedures are adequate in their level of detail. The inspectors determined that the licensee failed to follow this standard. The work order was inadequate and did not address a key aspect of the work, specifically, how the regulator was to be mounted given its incompatibility with the bracket.

The inspectors discussed the finding with the licensee and reviewed the licensees root cause analysis. The inspectors determined that the work package was inadequate because the licensee failed to appropriately plan the work activity. The planner was unaware of the fact that the mounting bracket was incompatible with the new regulator.

Analysis.

The licensees failure to incorporate significant details of a maintenance activity in a work package was a performance deficiency. The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective, in that, it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available. The finding has a human performance cross-cutting aspect associated with work control in that the licensee failed to appropriately plan the work activity H.3(a).

Enforcement.

This finding does not involve enforcement action because no regulatory requirements were violated. The licensee documented the finding in the corrective action program as Condition Report CR-2012-012183. The issue is being characterized as finding FIN 05000446/2013003-03, Failure to Properly Install an Air Regulator Causes Heater Drain Valve Closure and Reactor Trip.

4OA6 Meetings

Exit Meeting Summary

On April 4, 2013, the inspectors presented the results of the radiation safety inspections to Mr. R. Flores, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On April 9, 2013, the inspectors presented the inspection results of the review of inservice inspection activities to Mr. K. Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On July 10, 2013, the inspectors presented the resident inspection results to Mr. K. Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors acknowledged review of proprietary material during the inspection. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Flores, Senior Vice President and Chief Nuclear Officer

K. Peters, Site Vice President

S. Bradley, Manager, Radiation Protection

T. Gilder, Director, Performance Improvement

D. Goodwin, Director, Work Management

T. Hope, Manager, Nuclear Licensing

B. Kidwell, Manager, Emergency Preparedness

F. Madden, Director, Oversight and Regulatory Affairs

B. Mays, Vice President, Engineering

B. Moore, Director, Training

K. Nickerson, Director, Engineering Support

B. Patrick, Director, Maintenance

B. Reppa, Director, Site Engineering

S. Sewell, Director, Organizational Effectiveness

M. Smith, Director, Operations

S. Smith, Plant Manager

K. Tate, Manager, Security

D. Wilder, Director, Plant Support

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000445/2013003-01

05000446/2013003-01 NCV Inadequate Procedure for Testing the Main Steam Safety Valves (Section 1R15)

05000445/2013003-02 NCV Failure to Follow Procedure Results in Water Hammer (Section 4OA2.3)

05000446/2013003-03 FIN Failure to Properly Install an Air Regulator Causes Heater Drain Valve Closure and Reactor Trip (Section 4OA3)

Closed

05000446/2012-002-00 LER Unit 2 Automatic Reactor Trip due to Low Steam Generator Water Level (Section 4OA3)