IR 05000346/2017001

NRC Integrated Inspection Report 05000346/2017001, Notice of Violation, and Quarterly Assessment Letter

ML17132A193
Person / Time
Site:	Davis Besse
Issue date:	05/12/2017
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Boles B FirstEnergy Nuclear Operating Co
References
IR 2017001
Preceding documents:	ML17019A322 (19 January 2017)
Download: ML17132A193 (41)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 May 12, 2017 Mr. Brian Site Vice President

FirstEnergy Nuclear Operating Company

Davis-Besse Nuclear Power Station 5501 North State Rte. 2, Mail Stop A-DB-3080 Oak Harbor, OH 43449-9760 SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION-NRC INTEGRATED INSPECTION REPORT 05000346/2017001, NOTICE OF VIOLATION, AND QUARTERLY ASSESSMENT LETTER

Dear Mr. Boles:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Davis-Besse Nuclear Powe r Station. On April 10, 2017, the NRC inspectors discussed the results of this inspection with Mr. Brian Matty, Manager, Plant Engineering, and other members of your staff. The enclosed report documents the results of this inspection. Based on the results of this inspection, the NRC has identified one issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined that a violation is associated with this issue.

This violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). This violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice, consistent with the NRC Enforcement Policy, Section 2.3.2.a.2, because Davis-Besse Nuclear Power Station failed to restore compliance and failed to have objective plans to restore compliance in a reasonable time period following the NRC identification of an associated Non-Cited Violation (NCV) on June 26, 2014. The associated NCV was documented in Inspection Report (IR) 05000346/2014003 (ADAMS Accession Number ML14212A468) You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. Based on the results of this inspection, no other findings were identified. If you contest the violation or significance of the violation, you should provide a response as specified in the Notice. If you disagree with the cross-cutting aspect assignment to the 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 III, and the NRC Resident Inspector at the Davis-Besse Nuclear Power Station. To the extent possible, your response should not include any personal, privacy, or proprietary information so that it can be made available to the Public without redaction. In addition, the NRC completed its quarterly performance assessment of the Davis-Besse Nuclear Power Station, reviewing performance indicators (PIs), inspection results, and enforcement actions from January 1, 2017, through March 31, 2017. This letter informs you of the NRC's assessment of your facility during this period. The NRC concluded that overall performance at your facility preserved public health and safety. The NRC determined that the performance of Davis-Besse during the first quarter of 2017 was within the Regulatory Response Column of the NRC's Reactor Oversight Process (ROP) in Inspection Manual Chapter (IMC) 0305, "Operating Assessment Program" because of a White performance indicator (PI) in the Initiating Events Cornerstone. As required by the NRC ROP Action Matrix, a supplemental inspection was performed in accordance with Inspection Procedure (IP) 95001, "Supplemental Inspection Response to Action Matrix Column 2 Inputs." The purpose of the inspection was to examine the causes for, and actions taken related to the White PI in the Initiating Events Cornerstone. The inspection results were documented in IR 05000346/2017011, dated April 17, 2017, (ADAMS Accession No. ML17107A387). In the first quarter 2017 report of PIs, the Davis-Besse PI "Scrams with Complications" returned to a Green level. Based on the inspection results documented in IR 05000346/2017011 and

that the Davis-Besse Scrams with Complications PI returned to a Green level, the Davis-Besse

Nuclear Power Station transitioned to the Licensee Response Column of the NRC's ROP Action Matrix, effective the date of this letter, in accordance with the provisions of IMC 0305. This letter, its enclosure, and your response will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,

/RA/ Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects Docket No. 50-346 License No. NPF-3

Enclosures:

(1) Notice of Violation (2) IR 05000346/2017001

REGION III Docket No: 50-346 License No: NPF-3 Report No: 05000346/2017001 Licensee: FirstEnergy Nuclear Operating Company (FENOC) Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: January 1 through March 31, 2017 Inspectors: D. Mills, Senior Resident Inspector T. Briley, Resident Inspector P. Smagacz, Resident Inspector-Fermi Power Plant N. Feliz-Adorno, Senior Reactor Inspector G. O'Dwyer, Reactor Inspector J. Rutkowski, Project Engineer

Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects

SUMMARY

Inspection Report 05000346/2017001; 1/1/17 - 3/31/17; Davis-Besse Nuclear Power Station;

Heat Sink Performance. This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One (Green) finding was identified by the inspectors. The finding involved an associated Cited Violation of U.S. Nuclear Regulatory Commission (NRC) requirements. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015.

Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance (Green) and an associated Cited Violation of Title 10 of the Code of Federal Regulations , (10 CFR)

Part 50, Appendix B, Criterion XI, "Test Control," for the licensee's failure to establish a test program that demonstrates the emergency core cooling system (ECCS) room coolers will perform satisfactorily in service. Specifically, the associated inspection procedures did not include acceptance criteria, and the inspection results were not documented and evaluated to demonstrate the ECCS room coolers' thermal performance was acceptable. The licensee captured this issue in their corrective action program (CAP) as condition report (CR) 2017-03328 to, in part, restore compliance and assess current and past operability. The performance deficiency was determined to be more than-minor because it was associated with the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the failure to demonstrate the ECCS room coolers will perform satisfactorily in service does not ensure the coolers would remain available and capable of performing their mitigating function because it has the potential to allow an unacceptable condition to go undetected. The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems.

Specifically, the licensee re-evaluated the past operability impact of the 2016 tube blockage discoveries and determined that coolers were operable by crediting actual service water temperature and flowrate conditions. The inspectors determined that the associated finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. (Section 1R07.b(1)) [P.2]

3

REPORT DETAILS

Summary of Plant Status The unit began the inspection period operating at full power. On February 24, reactor power was reduced to 50 percent and remained at reduced power until February 27, to support main condenser maintenance. With the exception of small power maneuvers (e.g., reductions of 10 percent power or less) to facilitate planned evolutions and testing, the unit remained operating at or near full power for the balance of the inspection period.

REACTOR SAFETY

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

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Condition-Severe Thunderstorm Watch and Severe Thunderstorm Warning

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for the evening of February 24, 2017 and into the early morning of February 25, 2017, the inspectors reviewed the licensee's overall preparations/protection for the expected weather conditions. On February 24, 2017, the inspectors walked down the licensee's off-site power and emergency alternating current power systems because their safety-related functions could be affected or required as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the licensee staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Safety Analysis Report (USAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. The inspectors also reviewed a sample of CAP items to verify that the licensee-identified adverse weather issues at an appropriate threshold and dispositioned them through the CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report. This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

• the station's motor driven feedwater pump while auxiliary feedwater (AFW) train No. 2 was out of service for various preventative maintenance activities during the week ending January 21, 2017;

• electric fire pump while the diesel fire pump was out of service for corrective maintenance during the week ending January 28, 2017; and

• high pressure injection (HPI) train No. 1 while HPI train No. 2 was out of service for various preventative maintenance activities during the week ending January 28, 2017. The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, USAR, Technical Specification (TS) requirements, outstanding work orders (WOs), CRs, 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 CAP with the appropriate significance characterization. Documents reviewed are listed in the to this report. These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

5

• control room heating, ventilating, and air conditioning room; auxiliary building elevation 638' (Room 603 - Fire Area HH) during the week ending January 14, 2017;

• emergency core cooling system (ECC S) pump room 1-1; auxiliary building elevation 545' and 555' (Room 105 - Fire Area AB) during the week ending February 18, 2017;

• ECCS pump room 1-2; auxiliary building elevation 545' and 555' (Room 115 - Fire Area A) during the week ending March 18, 2017; and

• AFW Pump 2 Room; turbine building elevation 565' (Room 238 - Fire Area F) during the week ending March 18, 2017. The inspectors reviewed areas to assess if the licensee 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 implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the Attachment to this report, 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. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

.1 Triennial Review of Heat Sink Performance

a. Inspection Scope

The inspectors reviewed operability determinations, completed surveillances, vendor manual information, calculations, performance test and inspection results, and procedures associated with the ECCS room coolers and containment air coolers.

These coolers were chosen based, in part, on their risk significance in the licensee's probabilistic safety analysis, important safety-related mitigating system support functions, and operating history. For the selected coolers, the inspectors reviewed the methods used during testing, inspection, maintenance, and monitoring of biotic fouling and macrofouling. Specifically, the inspectors assessed the consistency of these methods with test conditions and 6 accepted industry practices or equivalent. In addition, the inspectors assessed the associated acceptance criteria and reviewed the documentation, evaluation, and disposition of as-found results. The inspectors also assessed the condition and operation of the coolers by considering design assumptions included in heat transfer calculations, such as tube plugging limits, and design basis information described in the USAR. This review also considered the potential for water hammer. The inspectors performed a walkdown of the ECCS room coolers and assessed their material condition. The inspectors reviewed the performance of the ultimate heat sink (UHS), safety-related component cooling water (CCW) system, and their subcomponents such as piping and valves. Specifically, the inspectors assessed the licensee's inspection of the UHS intended to identify degradation of the shoreline protection or loss of structural integrity and documentation associated with debris or sediment removal. In addition, the

inspectors reviewed analyses, monitoring ac tivities, hydrographic surveys, and dredging documentation intended to ensure sufficient UHS reservoir capacity. The inspectors

also performed a system walkdown of the CCW system to assess the licensee's structural integrity monitoring activities, reviewed CCW chemistry monitoring activities and verified the absence of any active thru wall pipe leaks since the last U.S. Nuclear Regulatory Commission (NRC) inspection. The inspectors also reviewed CCW system pressurization test results and operating logs, and interviewed operations and engineering staff to identify adverse CCW make-up trends that could be indicative of excessive leakage out of the closed system. In addition, the inspectors reviewed CAP documents related to the selected coolers and heat sink performance issues to assess the licensee's threshold for identifying issues and the effectiveness of the corrective actions. The documents that were reviewed are included in the Attachment to this report. These inspection activities constituted three heat sink inspection samples as defined in Inspection Procedure 71111.07-05.

b. Findings

(1) Failure to Establish a Test Program that Demonstrates the Emergency Core Cooling System Room Coolers Will Perform Satisfactorily in Service

Introduction:

A finding of very-low safety significance (Green) and associated Cited Violation of 10 CFR, Part 50, Appendix B, Criterion XI, "Test Control," was identified by the inspectors for the licensee's failure to establish a test program that demonstrates the ECCS room coolers will perform satisfactorily in service. Specifically, the associated inspection procedure did not include acceptance criteria, and inspection results were not documented and evaluated to demonstrate the ECCS room coolers thermal performance was acceptable.

Description:

On July 18, 1983, the NRC issued Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment," to alert licensees about operating experience and studies that raised concerns regarding service water (SW)systems in nuclear power plants. The GL requested licensees, in part, to provide a response describing the actions planned or taken to ensure that their SW systems were and will be maintained in compliance with applicable regulatory requirements.

The licensee provided its final response in a letter to the NRC titled, "Supplemental Response to GL 89-13," dated September 9, 1993. The response stated, in part, 7 "Toledo Edison [the licensee] has an on-going performance test program for heat exchangers at Davis-Besse Nuclear Power Station that is consistent with recommendation II of GL 89-13." This recommendation was to, "Conduct a test program to verify the heat transfer capability of all safety-related heat exchangers cooled by service water." The licensee established NOP-ER-2006, "Service Water Reliability Management Program," as the GL 89-13 program implementing procedure governing this test program. The test strategy for the safety-related ECCS room coolers was to inspect-and-clean when determined necessary based on performance testing trending.

The performance testing only measured differential pressure and flowrate on a quarterly

basis. On June 26, 2014, the inspectors identified that the licensee could not follow procedure NOP-ER-2006 because the ECCS room cooler inspection procedures did not include acceptance criteria. This issue was captured by the licensee in their CAP as CR 2014-10995 and was documented by the inspectors as Non-Cited Violation (NCV)05000346/2014003-04 in Inspection Report (IR) 05000346/2014003, dated July 31, 2014. The licensee closed CR 2014-10995 on October 15, 2015. On February 8, 2017, a licensee self-assessment discovered that the affected procedures (i.e., preventative maintenance (PM) 4801, PM 4802, PM 4803, and PM 4804) still did not include acceptance criteria and that the inspection results were not documented in a format that fully described the condition of the coolers. This discovery was captured in the CAP as CR 2017-01387. The associated actions intended to correct the issue were to develop the acceptance criteria and revise the PMs to include inspection results documentation instructions and the acceptance criteria. During this inspection period, the inspectors noted the PM revisions tracked by CR 2017-01387 would also add a note stating, "as-found acceptance criteria is not applicable for this order [PMs], as the results of as-found examination are to be documented for trending purposes only." It also stated "function of the room cooler is

demonstrated by performance testing per DB-PF-04736." However, the performance testing was designed as an inspect-and-clean trigger as opposed to a thermal performance demonstration. Specifically, it did not assess the available heat transfer area and fouling conditions. Thus, the actions taken under CR 2017-01387 would not correct the issue. In addition, the licensee did not assess the current and past operability of the coolers. The inspectors were particularly concerned because the licensee's CAP documented the discovery of blocked tubes during two inspections conducted in 2016 (i.e., CR 2016-14091 and CR 2016-13276), and incorrectly credited the performance testing results to conclude these discoveries were acceptable. The licensee captured the inspectors' concerns in the CAP as CR 2017-03328. The proposed corrective action to restore compliance at the time of this inspection was to evaluate the current ECCS room cooler test strategy, propose changes to demonstrate thermal performance, and re-evaluate the past-operability impact of the 2016 tube blockage discoveries. In addition, the licensee reasonably determined the coolers were operable at the time of the inspection based on the documented as-left conditions associated with the cleaning performed in the winter of 2016.

Analysis:

The inspectors determined that the failure to establish a test program that demonstrates the ECCS room coolers will perform satisfactorily in service was contrary to 10 CFR 50, Appendix B, Criterion XI, "Test Control," and was a performance deficiency. The performance deficiency was determined to be more than minor because 8 it was associated with the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the failure to demonstrate the ECCS room coolers will perform satisfactorily in service does not ensure the coolers would remain available and capable of performing their mitigating function because it has the potential to allow an unacceptable condition to go undetected. The inspectors determined the finding could be evaluated using the significance determination process in accordance with Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," issued on October 7, 2016. Because the finding impacted the Mitigating Systems and Barrier Integrity cornerstones, the inspectors screened the finding through IMC 0609 Appendix A, "The Significance Determination Process for Findings At-Power,"

issued on June 19, 2012, using Exhibit 2, "Mitigating Systems Screening Questions." The finding screened as of very-low safety signi ficance (Green) because it did not result in the loss of operability or functionality of mitigating systems. Specifically, the licensee re-evaluated the past-operability impact of the 2016 tube blockage discoveries and determined that coolers were operable by crediting actual SW temperature and flowrate conditions. This finding is being treated as NRC-identified in accordance with IMC 0612, "Power Reactor Inspection Reports." Specifically, although it was initially identified by the licensee, the inspectors identified inadequacies in the licensee's classification, evaluation, and correction of the issue. The inspectors determined that the associated finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee failed to document and evaluate inspection results against acceptance criteria because they did not thoroughly evaluate the issues documented in CR 2014-10995, CR 2016-14091, CR 2016-13276, and CR 2017-01387. [P.2]

Enforcement:

Title 10 CFR 50, Appendix B, Criterion XI, "Test Control," requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components (SSCs) will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. It also stated that test results shall be documented and evaluated to assure that test requirements have been satisfied. Contrary to the above, as of June 26, 2014, the licensee failed to assure that testing, required to demonstrate that the ECCS room coolers would perform satisfactorily in service, was identified and performed in accordance with written test procedures which incorporated the requirements and acceptance limits contained in applicable design documents. In addition, the licensee failed to document and evaluate the associated test results to assure that test requirements have been satisfied.

Specifically, PM 4801, PM 4802, PM 4803, and PM 4804 did not contain acceptance tube blockage and biofouling/silt deposit limits, and the associated inspection results 9 were not documented and evaluated to demonstrate the acceptability of the ECCS room coolers' thermal performance. The licensee is still evaluating its planned corrective actions. However, the inspectors determined that the continued non-compliance does not present an immediate safety concern because the licensee reasonably determined the coolers were operable based on a review of the most recent post-cleaning records. This violation is being cited as described in the Notice, which is enclosed with this IR. This is consistent with the NRC Enforcement Policy, Section 2.3.2.a.2, which states, in part, that the licensee must restore compliance within a reasonable period of time (i.e., in a timeframe commensurate with the significance of the violation) after a violation is identified. The NRC identified the origi nal issue on June 26, 2014, and dispositioned it as NCV 05000346/2014003-04 in IR 05000346/2014003, dated July 31, 2014. On March 23, 2017, the inspectors determined that the licensee failed to restore compliance within a reasonable time following the identification of this NCV and failed to have objective plans to restore compliance. (VIO 05000346/2017001-01, Failure to Establish a Test Program that Demonstrates the Emergency Core Cooling System Room Coolers Will Perform Satisfactorily in Service)

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On February 28, 2017, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crew's clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation during Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

During the course of the inspection period, the inspectors performed several observations of licensed operator performance in the plant's control room to verify that operator performance was adequate and that plant evolutions were being conducted in accordance with approved plant procedures. Specific activities observed that involved a heightened tempo of activities or periods of elevated risk included, but were not limited to:

• plant power maneuvers to 99.5 percent reactor thermal power for non-nuclear instrumentation steam generator No. 2 main feedwater flow module repair/replacement during the week ending January 28, 2017;

• control room response to unexpected fire alarm during the week ending February 13, 2017;

• manual bypass of low pressure feedwater heater 2-2 due to suspected tube leakage during the week ending February 25, 2017;

• plant power maneuvers to 50 percent and removal from service of main feed pump No. 1 in preparation for maintenance on main condenser during the week ending February 25, 2017; and

• plant power ascension to 100 percent and restoration of main feed pump No. 1, following maintenance on main condenser during the week ending March 4, 2017. The inspectors evaluated the following areas during the course of the control room observations:

• licensed operator performance;

• the crew's clarity and formality of communications;

• the ability to take timely actions in the conservative direction;

• the prioritization, interpretation, and verification of annunciator alarms;

• the correct use and implementation of normal operating, annunciator alarm response, and abnormal operating procedures by the crew;

• control board manipulations;

• the oversight and direction provided by on-watch senior reactor operators and plant management personnel; and

• the ability to identify and implement appropriate TS actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. These observation activities by the inspectors of operator performance in the station's control room constituted five quarterly licensed operator heightened activity/risk samples as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant system:

• decay heat pump 2 bearing performance. The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's 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) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for SSCs/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors also performed a quality review for the recent maintenance activities associated with decay heat pump 2 bearing oil, as discussed in IP 71111.12, Section 02.02. 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 CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related 12 equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• emergent repair and replacement activities associated with emergency ECCS room cooler 1 motor following unexpected energized motor test data of the replacement motor during the week ending January 28, 2017;

• emergent repair activities associated with component cooling water heat exchanger 3 outlet butterfly valve (CC33) flange misalignment following license renewal inspection during the weeks ending February 4, 2017, through

February 25, 2017;

• emergent repair activities associated with auxiliary feedwater (AFW) pump 2 governor repair during the week ending March 18, 2017; and

• isolation of, and bypass of, low-pressure feedwater heater 2-2 utilizing throttling of the heater bypass valve as evaluated in Operational Decision Making Issue 17-02 during the week ending March 18, 2017. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• the operability and functionality of high pressure injection (HPI) train 2 following identification of high recirculation flow during routine testing, as documented in CR 2017-00796;

• the operability and functionality of the AFW pump with the governor high speed/low speed stop switching functionality disabled as documented in CR 2017-02933; and

• the operability and functionality of the Intake structure and service water system housed therein with missile barriers removed for maintenance as documented in CR 2017-00532.

13 The inspectors selected these potential 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 TS 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 TS and Updated Safety Analysis Report (USAR) to the licensee's 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 eval uations. 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. Documents reviewed are listed in the Attachment to this report. This operability inspection constituted three samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 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:

• auxiliary feed pump train 1 following maintenance on the steam generator No. 2 to auxiliary feed pump turbine isolation valve and oil change;

• power range nuclear instrument calibration of nuclear instruments 5, 6, and 8 and associated heat balance checks during the week ending January 21, 2017;

• reactor trip breaker 'C' following breaker replacement during the week ending January, 28, 2017;

• SW pump No. 3 following motor refurbishment and replacement during the week ending February 4, 2017; and

• AFW pump No. 2 following governor repair/stepper motor replacement during the week ending March 18, 2017. These activities were selected based upon the SSC's ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various 14 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 in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report. This inspection constituted five post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural

and TS requirements:

• station blackout diesel generator 24-month periodic testing during the week ending February 18, 2017, (routine);

• periodic control rod exercising test during the week ending February 25, 2017, (routine);

• periodic at-power turbine valve testing during the week ending March 4, 2017, (routine);

• containment spray pump and valve quarterly testing during the week ending March 18, 2017, (routine);

• containment quarterly entry walkdown and closeout inspection during the week ending March 31, 2017, (routine); and

• containment personnel airlock seal leakage test during the week ending March 31, 2017, containment isolation valve (CIV). The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current; 15

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored

where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report. This inspection constituted five routine surveillance testing samples and one CIV sample as defined in IP 71111.22, Sections-02 and-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency preparedness drill on February 25, 2017, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the control room simulator, Technical Support Center, and Emergency Operations Facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare 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 CAP. As part of the 16 inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report. This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours performance indicator (PI) for the period from January 2016 to December 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports and NRC integrated inspection reports for the period to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator, and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted one unplanned scrams per 7000 critical hours sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Unplanned Scrams with Complications

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams with Complications performance indicator for the period from January 2016 to December 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports and NRC Integrated Inspection Reports for the period to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report 17 database to determine if any problems had been identified with the PI data collected or transmitted for this indicator, and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted one unplanned scrams with complications sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Unplanned Power Changes per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours performance indicator for the period from January 2016 to December 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs, issue reports, maintenance rule records, event reports and NRC Integrated Inspection Reports for the period to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator, and none were identified.

Documents reviewed are listed in the Attachment to this report. This inspection constituted one unplanned transients per 7000 critical hours sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensee's CAP at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensee's CAP as a result of the inspectors' observations; however, they are not discussed in this report. 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.

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 licensee's CAP. This review was accomplished through inspection of the station's daily CR packages. These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) NRC Temporary Instruction 2515/192; "Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems"

a. Inspection Scope

The objective of this performance based temporary instruction (TI) is to verify implementation of interim compensatory measures associated with an open phase condition (OPC) design vulnerability in electric power system for operating reactors.

The inspectors conducted an inspection to determine if the licensee had implemented the following interim compensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability. The inspectors verified the following:

• the licensee had identified and discussed with plant staff the lessons-learned from the OPC events at the US operating plants including the Byron station OPC event and its consequences. This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC

event;

• the licensee had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on off-site power sources credited for safe shutdown of the plant;

• the licensee had established and continue to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible OPC; and 19

• the licensee had ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, the licensee assessed and managed plant risk in accordance with 10 CFR 50.65(a)

(4) requirements.

b. Findings and Observations

No findings of significance were identified. The inspectors identified that the licensee conducted training with operations personnel to understand the industry experience with an open phase event. The licensee had not provided operator training for promptly diagnosing an open phase event beyond the existing training for responding to annunciator alarms. The licensee normally operates while at power with plant electrical busses powered from the main generator with power from the switchyard though two startup transformers as fully capable alternate sources. The licensee has an open phase monitoring system with each of the two startup transformers. In the event of an annunciator alarm, the associated annunciator procedures directs personnel to verify annunciators at the alarming transformer. Operator tours also require a daily visual inspection of conductors and switchyard equipment associated with the startup transformers. The licensee also schedules semi-annual thermography inspection of switchyard components with similar inspections after switchyard switching operations and after certain natural events, such as high winds, that might damage switchyard components. This TI is closed.

4OA6 Management Meetings

.1 Exit Meeting Summary On April 10, 2017, the inspectors presented the inspection results to Mr. Brian Matty and other members of the licensee staff.

The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings Interim exits were conducted for:

• On March 24, 2017, the inspectors presented the inspection results to Mr. D. Imlay, and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Boles, Site Vice President

K. Byrd, Director, Site Engineering

D. Blakely, Supervisor, Nuclear Engineering Analysis

T. Brown, Director, Site Performance Improvement

J. Cuff, Manager, Site Training

J. Cunnings, Manager, Site Maintenance

A. Dawson, Manager, Site Chemistry

D. Hartnett, Superintendent, Nuclear Operations

T. Henline, Manager, Site Projects

J. Hofelich, Supervisor Nuclear Supply Systems Engineering

D. Imlay, General Plant Manager

G. Laird, Manager, Site Operations

B. Matty, Manager, Plant Engineering

P. McCloskey, Manager, Site Regulatory Compliance

G. Michael, Manager, Design Engineering

D. Noble, Manager, Site Radiation Protection

G. Nordlund, Superintendent, Radiation Protection

W. O'Malley, Manager, Fleet Oversight

R. Oesterle, Superintendent, Nuclear Operations Services

R. Patrick, Manager, Site Work Management

B. Pollauf, Supervisor, Nuclear Plant Systems Engineering

J. Sturdavant, Regulatory Compliance

J. Vetter, Manager, Emergency Response

L. Willis, Manager, Site Protection

G. Wolf, Supervisor, Regulatory Compliance

K. Zellers, Manager, Technical Services Engineering

U.S. Nuclear Regulatory Commission J. Cameron, Chief, Reactor Projects Branch 4

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000346/2017001-01 VIO Failure to Establish a Test Program that Demonstrates the Emergency Core Cooling System Room Coolers Will

Perform Satisfactorily in Service

Closed TI 2515/192 TI Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems

Discussed

None

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that