IR 05000424/2015004

NRC Integrated Inspection Report 05000424/2015004, 05000425/2015004, and 07201039/2015001, October 01, 2015 Through December 31, 2015

ML16029A333
Person / Time
Site:	Vogtle, 07201039
Issue date:	01/29/2016
From:	Shane Sandal NRC/RGN-II/DRP/RPB2
To:	Taber B Southern Nuclear Operating Co
References
IR 2015001, IR 2015004
Download: ML16029A333 (31)

Text

January 29, 2016

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION

REPORT 05000424/2015004, 05000425/2015004, AND 07201039/2015001

Dear Mr. Taber:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection results which were discussed on January 25, 2016, with Mr. D. Myers and other members of your staff.

NRC inspectors documented one self-revealing finding of very low safety significance (Green) in this report. Further, inspectors documented a licensed-identified violation which was determined of very low safety significance in this report. These findings were determined to involve violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCV) consistent with Section 2.3.2 of the Enforcement Policy. If you contest these violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Vogtle Electric Generating Plant. In accordance with the 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, 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 the 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/

Shane Sandal, Chief Reactor Projects Branch 2 Division of Reactor Projects

Docket Nos.: 05000424, 05000425 and 07201039 License Nos.: NPF-68 and NPF-81

Enclosures:

Inspection Report 05000424/2015004, 05000425/2015004, and 07201039/2015001 w/Attachment: Supplementary Information

REGION II==

Docket Nos.:

50-424, 50-425

License Nos.:

NPF-68, NPF-81

Report Nos.:

05000424/2015004, 05000425/2015004, and 07201039/2015001

Licensee:

Southern Nuclear Operating Company, Inc. (SNC)

Facility:

Vogtle Electric Generating Plant, Units 1 and 2

Location:

Waynesboro, GA 30830

Dates:

October 01, 2015 through December 31, 2015

Inspectors:

M. Cain, Senior Resident Inspector

A. Alen, Resident Inspector

T. Chandler, Resident Inspector

D. Mas-Penaranda, Project Engineer

B. Caballero, Senior Operations Engineer (1R11)

P. Cooper, Reactor Inspector (1R08, 4OA5))

R. Carrion, Senior Reactor Inspector (1R08)

Approved by:

Shane Sandal, Chief Reactor Projects Branch 2 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000424/2015-004, 05000425/2015-004, and 07201039/2015-001; 10/01/2015 -

12/31/2015; Vogtle Electric Generating Plant, Units 1 and 2; Maintenance Effectiveness.

The report covered a 3-month period of inspection by resident inspectors. One Green finding was identified. The significance of inspection findings are 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 (SDP) dated April 29, 2015. The 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 NRCs Enforcement Policy dated February 4, 2015. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, revision 5. Documents reviewed which are not specifically identified in the Report Details are listed in the List of Documents Reviewed section of the Attachment.

Cornerstone: Mitigating Systems

• Green: A Green self-revealing NCV of TS 5.4.1, Procedures, was identified for the licensees failure to implement replacement schedules for 7300 process protection and control (PP&C) system cards in accordance licensee fleet maintenance procedures. As a result, failure of a 7300 PP&C card rendered the Unit 2 B train of nuclear service water system (NSCW) inoperable. The violation was entered into the licensees corrective action program as condition report (CR) 10124315 and corrective action report (CAR) 261373.

The failure to implement replacement schedules for 7300 PP&C system cards in accordance with maintenance procedure NMP-MA-015 was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective in that the failure of the 7300 PP&C card affected the availability of the Unit 2B train of NSCW. The finding screened as having very low safety significance (i.e. Green) because it did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time. No cross-cutting aspect was assigned to this finding because the inspectors determined that the cause of the finding was not indicative of current licensee performance because the licensee has established a change management process that would prevent the Performance Deficiency from occurring. (Section 1R12)

Violations of very low safety significance that were identified by the licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 was shut down for planned refueling outage at the beginning of the inspection period and restarted on October 21, 2015. On October 27, 2015, the unit was shut down to conduct repairs to the 6A feedwater heater. The unit was restarted on October 28, 2015, and attained full power on October 30, 2015. Unit 1 remained at or near full RTP for the remainder of the inspection period.

Unit 2 operated at or near full RTP for the entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Seasonal Extreme Weather Conditions: The inspectors conducted a detailed review of the stations adverse weather procedures written for extreme low temperatures for the following risk-significant systems. The inspectors verified that weather-related equipment deficiencies identified during the previous year had been placed into the work control process and/or corrected before the onset of seasonal extremes. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures before the onset seasonal extreme weather conditions.

• Unit 1 auxiliary feed water (AFW) system (both trains)

• Unit 2 emergency diesel generator (EDG) system (both trains)

Impending Adverse Weather Conditions: The inspectors reviewed the licensees preparations to protect risk-significant systems from severe weather conditions associated with a tornado watch issued by the National Weather Service on November 18, 2015. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures, including operator staffing, before the onset of and during the adverse weather conditions. The inspectors verified that operator actions specified in the licensees adverse weather procedure maintain readiness of essential systems. The inspectors verified that required surveillances were current, or were scheduled and completed, if practical, before the onset of anticipated adverse weather conditions. The inspectors also verified that the licensee implemented periodic equipment walkdowns or other measures to ensure that the condition of plant equipment met operability requirements.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdown: The inspectors verified that critical portions of the system below was correctly aligned by performing a partial walkdown. The inspectors selected this system for assessment because it had been recently realigned. The inspectors determined the correct system lineup by reviewing plant procedures and drawings.

• Unit 1 AFW system standby re-alignment following refueling outage startup operation

Complete Walkdown: The inspectors verified the alignment of the Unit 2 B and C trains of the AFW system. The inspectors selected this system for assessment because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents. The inspectors reviewed records related to the system outstanding design issues, maintenance work requests, and deficiencies. The inspectors verified that the selected system was correctly aligned by performing a complete walkdown of accessible components.

To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders, as well as periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports.

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Quarterly Inspection: The inspectors evaluated the adequacy of selected fire plans procedures by comparing the procedures to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans procedures, the inspectors assessed the following attributes.

• control of transient combustibles and ignition sources

• fire detection systems

• water-based fire suppression systems

• gaseous fire suppression systems

• manual firefighting equipment and capability

• passive fire protection features

• compensatory measures and fire watches

• issues related to fire protection contained in the licensees corrective action program The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment.

• Unit 1, nuclear service water system (NSCW) towers and mechanical and electrical tunnels, fire zones 145, 146, 146A, 160A, and 160B

• Unit 2, NSCW towers and mechanical and electrical tunnels, fire zones 145, 146, 146A, 160A, and 160B

• Unit 1, train A EDG building and fuel oil storage tank building, fire zones 161 and 163

• Unit 1, engineered safety features (ESF) chiller and normal air conditioning rooms, fire zones 125A, 126A, 135, 153, 178, 179, and 180

• North and south firewater pump houses, fire zones 530 and 531

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

a. Inspection Scope

Non-Destructive Examination Activities and Welding Activities

The inspectors reviewed implementation of the licensees inservice inspection (ISI)program for monitoring degradation of the reactor coolant system boundary, risk-significant piping and component boundaries, and containment boundaries in Unit 1.

The inspectors either directly observed or reviewed the following non-destructive examinations (NDEs) mandated by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code of Record: 2001 Edition with 2003 Addenda) to evaluate compliance with the ASME Code,Section XI and Section V requirements, and if any indications or defects were detected, to evaluate if they were dispositioned in accordance with the ASME Code or an NRC-approved alternative requirement. The inspectors also reviewed the qualifications of the NDE technicians performing the examinations to determine whether they were current, and in compliance with the ASME Code requirements.

• Magnetic Particle Examination, 14-inch Pressurizer Surge Nozzle Weld to Lower Head, 11201-V6-002-W16, Class 2 (observed)

• Ultrasonic Examination (UT), 14-inch Pressurizer Surge Nozzle Inner Radius,11201-V6-002-IR-06, Class 2 (observed)

• Visual Examination (VT-1), Reactor Vessel Head Closure Washers, 11201-V6-001-S01 thru S054, Class 2 (observed)

• VT-1, Reactor Vessel Head Closure Head Nuts, 11201-V6-001-N01 thru N054, Class 2 (observed)

• VT-2, Reactor Vessel Closure Head Exterior, 11201-V6-CRDM, Class 1 (reviewed)

• VT-3, Reactor Vessel Closure Head Interior, 11201-V6-001-I02, Class 1 (reviewed)

The inspectors reviewed the following welding activities, qualification records, and associated documents in order to evaluate compliance with procedures and the ASME Code,Section XI and Section IX requirements. Specifically, the inspectors reviewed the work order (WO), repair and replacement plan, weld data sheets, welding procedures, procedure qualification records, welder performance qualification records, and NDE reports.

• WO SNC396173, Seal Weld on 1-1208-U4-033 2.5 Check Valve, Class 1

• WO SNC 659721, Butt Weld on 1-HV-9556B 0.5 Valve, Class 2

During non-destructive surface and volumetric examinations performed since the previous refueling outage, the licensee did not identify any relevant indications that were analytically evaluated and accepted for continued service; therefore, no NRC review was completed for this inspection procedure attribute.

Pressurized Water Reactor Vessel Upper Head Penetration Inspection Activities: The inspectors verified that for the Unit 1 vessel head, a bare metal visual examination was required during this outage, in accordance with the requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D). The inspectors reviewed the calculation of effective degradation years, the previous examination history, and reviewed the results of the VT-2 examination performed under the vessel head insulation, to verify that the examinations were performed in accordance with the requirements of ASME Code,Section XI, Article IWA-2212 requirements, and the frequency was consistent with the Code Case. The licensee did not identify any relevant indications that were accepted for continued service. Additionally, the licensee did not perform any welding repairs to the vessel head penetrations since the beginning of the last Unit 1 refueling outage; therefore, no NRC review was completed for these inspection procedure attributes.

Boric Acid Corrosion Control Inspection Activities: The inspectors reviewed the licensees boric acid corrosion control (BACC) program activities to determine if the activities were implemented in accordance with the commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants, and applicable industry guidance documents.

Specifically, the inspectors performed an onsite records review of procedures, and the results of the licensees containment walkdown inspections performed during the current refueling outage. The inspectors also interviewed the BACC program owner, conducted an independent walkdown of containment to evaluate compliance with licensees BACC program requirements, and verified that degraded or non-conforming conditions, such as boric acid leaks, were properly identified and corrected in accordance with the licensees BACC and corrective action programs (CAPs).

The inspectors reviewed Technical Evaluation #284012, Boric Acid Leakage/Residue on 11204U4117, to determine if the licensee properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity, in accordance with the licensee procedures. The inspectors also reviewed the condition reports (CRs) listed in the Attachment and associated corrective actions related to evidence of boric acid leakage, to evaluate if the corrective actions completed were consistent with the requirements of the ASME Code and 10 CFR Part 50, Appendix B, Criterion XVI.

Steam Generator Tube Inspection Activities: The inspectors reviewed the eddy current (EC) examination activities performed in Unit 1 steam generators (SGs) 2 and 3 during the current refueling outage to verify compliance with the licensees Technical Specifications (TSs), ASME BPVC Section XI, and Nuclear Energy Institute 97-06, Steam Generator Program Guidelines. The typical Vogtle Unit 1 SG inspections consist of 100 percent full-length bobbin inspections of two SGs every other outage combined with a +Point' program in all four SGs to address areas unable to be assessed by bobbin. Therefore, the inspectors noted that for SGs 1 and 4, a +Point' probe was utilized for Row 1 and Row 2 as an area of special interest.

The inspectors reviewed the scope of the EC examinations, and the implementation of scope expansion criteria, to verify that they were consistent with the Electric Power Research Institute (EPRI) Pressurized Water Reactor Steam Generator Examination Guidelines, Revision 7. The inspectors reviewed documentation for a sample of EC data analysts, probes, and testers to verify that personnel and equipment were qualified to detect the applicable degradation mechanisms, in accordance with the EPRI Examination Guidelines. This review included a sample of site-specific Examination Technique Specification Sheets (ETSSs) to verify that their qualification and site-specific implementation were consistent with Appendix H or I of the EPRI Examination Guidelines. The inspectors also reviewed a sample of EC data for selected SG tubes with a qualified data analyst to confirm that data analysis and equipment configuration were performed in accordance with the applicable ETSSs and site-specific analysis guidelines. The inspectors reviewed data to verify that recordable indications were detected and sized in accordance with vendor procedures.

The inspectors selected a sample of degradation mechanisms from the Unit 1 Degradation Assessment report and verified that their respective in-situ pressure testing criteria were determined in accordance with the EPRI Steam Generator Integrity Assessment Guidelines, Revision 3. In addition, the inspectors reviewed EC indication reports to determine whether tubes with relevant indications were appropriately screened for in-situ pressure testing. The inspectors also compared the latest EC examination results with the last Condition Monitoring and Operational Assessment report for Unit 1 to assess the licensees prediction capability for maximum tube degradation and number of tubes with indications. The inspectors verified that the licensees evaluation to verify it was conservative, and that current examination results were bound by the Operational Assessment projections.

The inspectors assessed the latest EC examination results to verify that new degradation mechanisms, if any, were identified and evaluated before plant startup.

The review of EC examination results included the disposition of potential loose part indications on the SG secondary side to verify that corrective actions for evaluating and retrieving loose parts were consistent with the EPRI Guidelines. Also, the inspectors normally review a sample of primary-to-secondary leakage data for Unit 1 to confirm that operational leakage in each SG remained below the detection or action level threshold, during the previous operating cycle. However, there had been no primary-to-secondary during the previous operating cycle; therefore, there was no data to review.

The inspectors review included the implementation of tube repair criteria and repair methods to verify that they were consistent with plant TSs and industry guidelines. The inspectors reviewed data to verify that the licensee had selected the appropriate tubes for plugging based on the required plugging criteria. The inspectors reviewed the tube plugging procedure and a sample of tube plugging results for tubes 2R41C102,

3R20 C54, and 3R45C62, to determine if the licensee installed the tube plugs in

accordance with the applicable procedures.

Furthermore, the inspectors interviewed licensee staff and reviewed a sample of inspection results for the inspection conducted in the secondary side internals of SGs 2 and 3, to verify that potential areas of degradation based on site-specific operating experience were inspected and appropriate corrective actions were taken to address degradation indications. This review included the results of Foreign Object Search and Retrieval activities in all four SGs and an evaluation for a potential loose part in the secondary side of each of the four SGs.

Identification and Resolution of Problems: The inspectors reviewed a sample of ISI-related issues entered into the CAP to determine if the licensee had appropriately described the scope of the problem, and had initiated corrective actions. The review also included the licensees consideration and assessment of operating experience events applicable to the plant. The inspectors performed this review to ensure compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action requirements.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

Annual Review of Licensee Requalification Examination Results: On September 4, 2015, the licensee completed the annual requalification operating examinations, which are required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses. The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11.

Resident Inspector Quarterly Review of Licensed Operator Requalification: The inspectors observed evaluated simulator scenario V-RQ-SE-15601 and static simulator exercise SS-28, administered to a licensed operating crew, on November 18, 2015, in accordance with the licensees accredited requalification training program. The inspectors assessed the following attributes.

• licensed operator performance

• the ability of the licensee to administer the scenario and evaluate the operators

• the quality of the post-scenario critique

• simulator performance

Resident Inspector Quarterly Review of Licensed Operator Performance: The inspectors observed licensed operator performance in the Unit 1 main control room on October 21, 2015 during the reactor startup following the refueling outage. The inspectors assessed the following attributes.

• use of plant procedures

• control board manipulations

• communications between crew members

• use and interpretation of instruments, indications, and alarms

• use of human error prevention techniques

• documentation of activities

• management and supervision

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed the licensees treatment of the three issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.

• Unit 1, turbine-driven AFW (TDAFW) pump, maintenance rule functional failure due to a signal inverter failure in the control system

• Unit 1, TDAFW pump, maintenance rule functional failure due to an inboard bearing oil gauge sightglass leak

• Unit 2, NSCW B train, maintenance rule functional failure due a 7300 printed circuit board card failure

b. Findings

Introduction:

A Green self-revealing NCV of TS 5.4.1, Procedures, was identified for the licensees failure to implement replacement schedules for 7300 process protection and control (PP&C) system cards in accordance licensee fleet maintenance procedure.

As a result, failure of a 7300 PP&C card rendered the Unit 2 B train of (NSCW)inoperable.

Description:

On September 20, 2015, Unit 2 control room operators received a power supply failure alarm on the balance-of-plant process control cabinet. Operators noted the B train of NSCW tower return spray valve (2HV-1669A) had closed and bypass valve (2HV-1669B) had opened. The licensee declared the NSCW train inoperable and determined that the 7300 PP&C card for temperature switch TSH-1669/TSL-1669 had failed. The temperature switch provided input to the NSCW spray valve to open/close based on return water temperature. The 7300 PP&C card failure resulted in sending a close signal to the NSCW tower spray valve. As the spray valve would no longer open based on temperature, it affected the NSCW and ultimate heat sink capability for removing heat from safety-related components. The failed card was replaced and spray valve alignment restored at 0230 on September 21, 2015.

The licensee identified the card had been in service for approximately 25 years and failed due to component aging. Licensee fleet procedure NMP-MA-015, 7300 Process Protection and Control System Printed Circuit Board Management version 1.0, required a one-time replacement of these cards prior to exceeding vendor recommended service life of 20 years. The licensee determined that since issuance of NMP-MA-015 in March 2011, the existing 7300 PP&C card maintenance strategy did not incorporate the replacement strategy in NMP-MA-015. Therefore, the card should have been replaced prior to failure.

Analysis:

The failure to implement replacement schedules for 7300 PP&C system cards in accordance with maintenance procedure NMP-MA-015 was a performance deficiency.

The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective in that the failure of the 7300 PP&C card affected the availability of the Unit 2B train of NSCW. The finding was evaluated using Exhibit 2, Mitigating Systems Screening Questions to IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012. The finding screened as having very low safety significance (i.e.

Green) because it did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time. No cross-cutting aspect was assigned to this finding because the inspectors determined that the cause of the finding was not indicative of current licensee performance because the licensee has established a change management process that would prevent the Performance Deficiency from occurring.

Enforcement:

Technical Specification 5.4.1 states, 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, dated February 1978.

Regulatory Guide 1.33, Appendix A, Section 9.b, Procedures for Performing Maintenance, states, in part, that preventive maintenance schedules should be developed to specifyinspection or replacement of parts that have a specific lifetime.

Licensee fleet maintenance procedure NMP-MA-015, 7300 Process Protection and Control System Printed Circuit Board Management version 1.0, required a one-time replacement of 7300 PP&C cards associated with the NSCW tower return spray valves.

Contrary to the above, since March 2011, the licensee did not establish and implement preventive maintenance replacement schedules for 7300 printed circuit board as specified in NMP-MA-015, including those associated with the NSCW tower return spray valves. As result, on September 20, 2015, the Unit 2 NSCW train B was rendered inoperable when a 7300 NAL card failed on the tower spray return valve. The licensee replaced the failed card and restored the affected train to operable status. The licensee scheduled replacement of NSCW spray valve 7300 cards for both NSCW trains in both units and conduct an extent of condition to identify 7300 cards that would require replacement per NMP-MA-015. Because this violation was of very low safety significance and was entered into the licensees CAP as CR10124315, and CAR261373 this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000424, 425/2015004-01, Failure to Implement Preventive Maintenance Procedure for 7300 Process Protection and Control System Printed Circuit Board.)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the maintenance activity listed below to verify that the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.

• Unit 1, October 15-16, 2015 YELLOW Outage Risk Assessment Monitor (ORAM)risk condition due to mid-loop operation

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors selected the six operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.

• Unit 1, immediate determination of operability (IDO) for residual heat removal pump motor train A due to bearing oil found on motor windings, CR10135701

• Unit 1, IDO for component cooling water (CCW) pump (11203P4005) for cracks found on the C-phase phenolic brace of the pumps breaker, CR10144495

• Unit 1, prompt determination of operability (PDO) for emergency diesel generator train A due to a jacket water leak on the left bank no. 8 cylinder, CR10124867

• Unit 1, thermal sleeve guide funnel separation operability assessment, LTR-RIDA-15-208

• Unit 2, IDO for battery charger (2BD1CB) DC output breaker trip, CR10141719

• Units 1 and 2, functionality assessment for safety injection pump room flood wall penetrations due to higher design flood level, CAR 259751

Operator Work-Around Annual Review: The inspectors performed a detailed review of the licensees operator work-around, operator burden, and control room deficiency lists for the station in effect the week of November 16, 2015 to verify that the licensee identified operator workarounds at an appropriate threshold and entered them in the corrective action program. The inspectors verified that the licensee identified the full extent of issues, performed appropriate evaluations, and planned appropriate corrective actions. The inspectors also reviewed compensatory actions and their cumulative effects on plant operation.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modifications did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications.

• LDCR 2015042, Technical Specification Bases change to allow use of WCAP-8648-A as an acceptable method of measuring axial offset using in-core detectors for the performance of surveillance requirement (SR) 3.3.1.3, 10/23/15

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors either observed post-maintenance testing or reviewed the test results for the four maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.

• Maintenance Work Order (MWO) SNC715338, Replacement of AX4 relay on Unit 1 train A NSCW system return header spray valve, 1HV1668A, 10/13/15

• MWO SNC120828, Repack pressurizer spray bypass valve, 1201-U4-090, 10/22/15

• MWO SNC709656, Inside containment reactor coolant system sampling valve, 1HV3548, repair, 10/22/15

• MWO SNC726254, Disassembly, cleaning, and re-assembly of Unit 1 NSCW pump no. 6 motor cooler flow orifice, 11/7/15

The inspectors evaluated these activities for the following:

• Acceptance criteria were clear and demonstrated operational readiness.

• Effects of testing on the plant were adequately addressed.

• Test instrumentation was appropriate.

• Tests were performed in accordance with approved procedures.

• Equipment was returned to its operational status following testing.

• Test documentation was properly evaluated.

Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

For the Unit 1 refueling outage, which continued from October 01, 2015 through October 21, 2015, the inspectors evaluated the following outage activities:

• refueling, heatup, and startup

• reactor coolant system instrumentation and electrical power configuration

• reactivity and inventory control

• decay heat removal and spent fuel pool cooling system operation

• containment closure

The inspectors verified that the licensee:

• controlled plant configuration in accordance with administrative risk reduction methodologies

• developed work schedules to manage fatigue

• developed mitigation strategies for loss of key safety functions

• adhered to operating license and technical specification requirements

Inspectors verified that safety-related and risk-significant structures, systems, and components not accessible during power operations were maintained in an operable condition. The inspectors also reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with outage activities.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the five surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing.

Routine Surveillance Tests

• 14666-1 Ver. 39, Train A Diesel Generator and ESFAS Test In-Service Tests (IST)

• 14808B-1 Rev. 5.0, Train B Centrifugal Charging Pump and Check Valve IST and Response Time Test

Containment Isolation Valve Tests

• 14387-1 Rev. 7, Containment Penetration No. 87 ILRT Pressurization Line Local Leak Rate Test

• 14340-1 Ver. 10, Containment Penetration No. 40 Fire Protection Water Supply Local Leak Rate Test

• 24905-C Ver. 34, Personnel Airlock Leak Rate Test (Unit 1)

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between October 1, 2014, and September 30, 2015 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures.

The inspectors verified the accuracy of reported data that were used to calculate the value of each PI. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data.

Cornerstone: Mitigating Systems

• safety system functional failures

• emergency AC power system

• cooling water system

b. Findings

No findings identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

The inspectors screened items entered into the licensees corrective action program in order to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.

.2 Annual Follow-up of Selected Issues

The inspectors conducted a detailed review of condition report CR 10141951, Entry into abnormal operating procedure 18000-C, Pressurizer Spray, Safety, or Relief Valve Malfunction, due to lowering pressurizer pressure, 11/2/2015. The inspectors evaluated the following attributes:

• complete and accurate identification of the problem in a timely manner

• evaluation and disposition of operability and reportability issues

• consideration of extent of condition, generic implications, common cause, and previous occurrences

• classification and prioritization of the problem

• identification of root and contributing causes of the problem

• identification of any additional condition reports

• completion of corrective actions in a timely manner

.3 Semi-Annual Trend Review

The inspectors reviewed issues entered in the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on human performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of July 2015 thru December 2015 although some examples extended beyond those dates when the scope of the trend warranted.

The inspectors compared their results with the licensees analysis of trends.

Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.

b. Findings

No findings were identified.

4OA5 Other Activities

Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation (60853)

a. Inspection Scope

The inspectors conducted a review of licensee and vendor activities in preparation for the concrete placement for the second small Independent Spent Fuel Storage Installation (ISFSI) pad upon which the HI-STORM (Holtec International Storage Module) FW (Flood and Wind) System will be sited to house spent fuel generated by the licensee. The inspectors walked down the construction area of the ISFSI pad and examined the rebar installation to verify that the rebar size, spacing, splice length, and concrete coverage on the top, side, and bottom complied to licensee-approved drawings, specifications, procedures, and other associated documents, and that compliance to applicable codes, the Certificate of Compliance (CoC), and Technical Specifications (TSs) was met. The inspectors also evaluated the concrete formwork installation for depth, straightness, and horizontal bracing to verify the overall dimensions and orientation for compliance to the licensee-approved drawings. The inspectors interviewed licensee and contract personnel to verify knowledge of the planned work. The inspectors also observed the actual concrete placement and vibration for the western half of the ISFSI slab, and observed tests for concrete slump and air content, temperature measurements, and the collection/preparation of cylinder samples for compression tests, to verify that the work was implemented according to approved specifications and procedures. The inspectors later returned to the freshly poured pad to verify that the pad was being cured according to approved specifications and Code requirements. Following completion of the 7-day and 28-day compression tests were completed by the independent laboratory, the inspectors reviewed the results to verify that the acceptance criteria were met. The inspectors noted that all tested samples satisfied the acceptance criteria.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

a.

Exit Meeting

On January 25, 2016 the resident inspectors presented the inspection results to Mr. D.

Myers and other members of plant staff. The inspectors confirmed that proprietary information was destroyed or returned following the completion of the inspection period.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation.

• Title 10 CFR Part 50.54(q)(2), required, in part, a licensee shall follow and maintain the effectiveness of its emergency plan that meet the standards of 10 CFR 50.47(b).

10 CFR 50.47(b)(4), required, in part, a standard emergency classification and action level scheme, the bases of which include facility and system effluent parameters, is in use by the nuclear facility licensee. Contrary to the above, from April 2002 to September 2015, the licensee failed to maintain the effectiveness of its emergency plan. Procedure 43014-C, Special Radiological Controls, version 53, specified non-conservative dose rates used to verify if RCS activity exceeded the threshold value for an emergency classification FA1 (Alert), loss of fuel clad barrier, in response to a chemical volume control system (CVCS) letdown process line high radiation alarm. The licensee entered this violation into the corrective action program as CR 10124780. The inspectors determined this violation was of very low safety significance (Green) because the finding did not constitute a failed risk-significant planning standard (RSPS).

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

T. Baker, Security Manager

C. Blackburn, SNC Steam Generator Engineer

S. Briggs, Operations Director

D. Brown, Corporate Outage Services

D. Caldwell, ISFSI Project Manager

J. Dixon, Radiation Protection Manager

B. Evans, Corporate Outage Services

G. Fechter, Welding Engineer

T. Fowler, Chemistry Manager

E. Groves, Corporate ISI Engineer

G. Gunn, Regulatory Affairs Manager

M. Henson, Operations Training Manager

S. Kowalski, Systems Engineering Manager

K. Morrow, Licensing Engineer

D. Myers, Plant Manager

R. Page, ISFSI Project

W. Phillips, Dry Cask Storage - Corporate

J. Santana, Programs Engineer

T. Smith, SNC NDE Level III/QDA

D. Stiles, Training Director

J. Summy, Engineering Director

D. Sutton, Manager of Site Projects

K. Taber, Site Vice-President

C. Thomas, Corporate Engineer

J. Thomas, Work Management Director

K. Walden, Licensing Engineer

S. Waldrup, Regulatory Affairs Manager

NRC

J. Rivera-Ortiz, Senior Reactor Inspector

LIST OF REPORT ITEMS

OPEN AND CLOSED

NCV

05000424/425/2015004-01 Failure to Implement Preventive Maintenance Procedure for 7300 Process Protection and Control System Printed Circuit Board (Section 1R12)