IR 05000369/2007004

IR 05000369-07-004 & 05000370-07-004; Duke Energy Corporation; 07/01/2007 Through 09/30/2007; McGuire Nuclear Station, Unit 1 and 2 Integrated Inspection Report

ML072950269
Person / Time
Site:	Mcguire, McGuire
Issue date:	10/22/2007
From:	Moorman J NRC/RGN-II/DRP/RPB1
To:	Gordon Peterson Duke Power Co
References
IR-07-004
Download: ML072950269 (28)

Text

October 22, 2007

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000369/2007004 AND 05000370/2007004

Dear Mr. Peterson:

On September 30, 2007, the US Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station. The enclosed report documents the inspection findings which were discussed on October 4, 2007, with you and members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two findings which were categorized as Severity Level IV violations under traditional enforcement. However, because of their very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV) consistent with Section VI.A of the NRC Enforcement Policy. If you contest any of these non-cited violations, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the McGuire facility.

DPC

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

James H. Moorman, III, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.:

50-369, 50-370 License Nos.: NPF-9, NPF-17

Enclosure:

NRC Integrated Inspection Report 05000369/2007004 and 05000370/2007004 w/Attachment - Supplemental Information

REGION II==

Docket Nos:

50-369, 50-370 License Nos:

NPF-9, NPF-17 Report Nos:

05000369/2007004 and 05000370/2007004 Licensee:

Duke Energy Corporation Facility:

McGuire Nuclear Station, Units 1 and 2 Location:

12700 Hagers Ferry Road Huntersville, NC 28078 Dates:

July 1, 2007 through September 30, 2007 Inspectors:

J. Brady, Senior Resident Inspector R. Eul, Resident Inspector Approved by:

James H. Moorman, III Reactor Projects Branch 1 Division of Reactor Projects

Enclosure SUMMARY OF FINDINGS IR05000369/2007004, IR05000370/2007004; 07/01/2007 - 09/30/2007; McGuire Nuclear Station, Units 1 and 2; Operability Evaluations and Other Activities.

The report covered a three month period of inspection by resident inspectors. Two severity level (SL) IV non-cited violations (NCV) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

A.

NRC-Identified and Self-Revealing Findings Cornerstone: Mitigating Systems

• SL4. The inspectors identified a non-cited violation of 10 CFR 50.59 for removing the approved seismic qualification methodology (WCAP-8110, supplement 9) from the Updated Final Safety Analysis Report (UFSAR) without performing a written safety evaluation. This issue is in the licensees corrective action program as PIP M-07-5016.

The failure to perform a written safety evaluation for changes made to the facility as described in the UFSAR is more than minor because there was a reasonable likelihood that the change requiring a 10 CFR 50.59 written safety evaluation would require Commission review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2). This likelihood is based on the November 21, 1974, NRC Safety Evaluation Report for WCAP-8110 Supplement 9, which stated the WCAP is considered an accepted methodology to demonstrate the continued adequacy of ice retention characteristics of the ice baskets when used as a reference for license applications. Removal of this approved methodology from the licensing basis would constitute a change in methodology and would require NRC review and approval. This issue was treated as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. It was characterized as a severity level IV violation because it was evaluated as not having greater than very low safety significance. (Section 1R15)

Other Activities: Operation of Independent Spent Fuel Storage Installation

• SL4. The inspectors identified a non-cited violation of 10 CFR 72.172 for failing to promptly identify and correct a condition adverse to quality associated with not performing 10 CFR 72.48(c) evaluations on five previous revisions of 10 CFR 72.212 written evaluations for the Independent Spent Fuel Storage Installation (ISFSI). This issue is in the licensees corrective action program as PIP M-07-4321.

This issue is greater than minor because the failure to promptly correct and perform 10 CFR 72.48(c) evaluations on any changes to 10 CFR 72.212 written evaluations had a reasonable likelihood that the changes could require NRC review and approval. This issue was considered as traditional enforcement because it had the potential for impacting the NRCs ability to perform its

Enclosure regulatory function. It was characterized as a severity level IV violation because it was evaluated as not having greater than very low safety significance. This finding has a cross-cutting aspect of timely correct action in the area of problem identification and resolution P.1.d]. (Section 4OA5)

B.

Licensee-Identified Violations None.

Enclosure Report Details Summary of Plant Status:

Unit 1 began the inspection period at approximately 100 percent rated thermal power (RTP) and remained there for the duration of the inspection period.

Unit 2 began the inspection period at approximately 100 percent RTP and remained there for the duration of the inspection period.

1.

REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection

.1 Impending Adverse Weather a.

Inspection Scope When a severe thunderstorm warning was predicted for the site on July 10, 2007, the inspectors reviewed actions taken by the licensee in accordance with procedure RP/0/A/5700/006, Natural Disasters. This was done prior to the onset of that weather, to determine whether the adverse weather conditions could either initiate a plant event or prevent any structure, system, or component (SSC) from performing its design function.

b.

Findings No findings of significance were identified.

.2 Seasonal Adverse Weather a.

Inspection Scope After the licensee completed preparations for seasonal high temperature, the inspectors discussed and reviewed the licensees Hot Weather Program, Hot Weather Computer Spreadsheet, and Hot Weather Action Item Register for 2007 with the licensees program owner and on-shift licensed operators. The inspectors reviewed the completed test results for PT/0/B/4700/039, Warm Weather Equipment Checkout, dated April 1, 2007. Because there was no safety-related equipment affected by hot weather, the inspectors toured the plant to determine if other risk significant equipment not monitored by the program could be affected. Documents reviewed are listed in the Attachment to this report.

b.

Findings No findings of significance were identified.

Enclosure 1R04 Equipment Alignment a.

Inspection Scope The inspectors performed a partial walkdown of the four systems listed below to assess the operability of redundant or diverse trains and components when safety equipment was inoperable. 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, walked down control system components, and determined whether selected breakers, valves, and support equipment were in the correct position to support system operation. The inspectors also determined whether the licensees corrective action program had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers. Documents reviewed are listed in the Attachment to this report.

• Unit 1 train B Charging System with train A out of service on July 3

Unit 1 train B Containment Spray System with train A out of service on July 3

Unit 2 train A Auxiliary Feedwater System with train B out of service on July 10

Unit 2 train A Emergency Diesel Generating (EDG) System with train B out of service on July 10 b.

Findings No findings of significance were identified.

1R05 Fire Protection

.1 Fire Protection - Tours a.

Inspection Scope For the six areas identified below, the inspectors reviewed the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures, to determine whether those items were consistent with Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire Protection System, and the fire protection program as described in the Design Basis Specification for Fire Protection (MCS-1465.00-00-0008). The inspectors walked down accessible portions of each area, as well as reviewed the associated pre-fire plan strategy and results from related surveillance tests, to determine whether conditions in these areas were consistent with descriptions of the areas in the Design Basis Specification. Documents reviewed during this inspection are listed in the Attachment to this report.

Enclosure The inspected areas included:

Unit 1 Auxiliary Building Electrical Penetration Room (Fire Area 15)

Unit 2 Auxiliary Building Electrical Penetration Room (Fire Area 16)

Unit 1 Interior Doghouse (Fire Area 28)

Unit 2 Interior Doghouse (Fire Area 29)

Unit 1 Exterior Doghouse (Fire Area 30)

Unit 2 Exterior Doghouse (Fire Area 31)

b.

Findings No findings of significance were identified.

.2 Fire Protection - Drill Observation a.

Inspection Scope The inspectors observed one fire drill on August 29, 2007. The drill was observed to evaluate the readiness of the plant fire brigade to fight fires. The inspectors determined whether the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were: (1) proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use and layout of fire hoses; (3) employment of appropriate fire fighting techniques; (4) sufficient fire fighting equipment brought to the scene; (5) effectiveness of fire brigade leader communications, command, and control; (6) search for victims and propagation of the fire into other plant areas; (7) smoke removal operations; (8) utilization of pre-planned strategies; (9) adherence to the pre-planned drill scenario; and (10) drill objectives.

The inspectors reviewed the following Problem Investigation Process reports (PIPs)

associated with this area, to determine whether the licensee identified and implemented appropriate corrective actions:

PIP M-07-4494, Fire Brigade Turnout Gear Missing

PIP M-07-4668, Critique of A Shift Fire Drill b.

Findings No findings of significance were identified.

Enclosure 1R06 Flood Protection Measures

.1 External Flooding a.

Inspection Scope The inspectors walked down the outside portions of the plant in the vicinity of the auxiliary building, which are susceptible to flooding from external sources, to determine whether the area configuration, features, and equipment functions were consistent with the descriptions and assumptions used in UFSAR Section 2.4.10, Flood Protection Requirements, and in the supporting basis documents listed in the Attachment to this report. This review entailed: (1) potential flooding affects from probable maximum flooding on the auxiliary building (AB); (2) potential flooding affects of cable trenches, cable pits, and manholes; (3) potential failure of the auxiliary feedwater storage tanks (CAST) and flooding of the turbine building, diesel generator area, and the yard.

In addition, the inspectors reviewed preventive maintenance for manholes that contain cables important to safety and were subject to flooding. This was done to determine whether cables and associated support equipment described in the UFSAR were not damaged by submergence and would perform their intended function.

b.

Findings No findings of significance were identified.

.2 Internal Flooding a.

Inspection Scope The inspectors walked down the auxiliary building residual heat removal and containment spray pump area (695 foot-elevation) and the internal and external doghouses. These areas contain risk-significant equipment which are below flood levels or otherwise susceptible to flooding from postulated pipe breaks. The inspectors assessed whether the area configuration, features, and equipment functions were consistent with the descriptions and assumptions used in associated UFSAR sections and in the supporting basis documents listed in the Attachment to this report. The inspectors also did a general walk-through of the auxiliary building to inspect the licensees determination that pipe breaks in the auxiliary building would drain to the auxiliary building areas identified above. The inspectors reviewed preventive maintenance documentation for the sump pumps and level transmitters in the groundwater drainage system to determine whether the system equipment was being adequately maintained to perform its design function of mitigating flooding. The inspectors reviewed the operator actions credited in the flooding analysis and contained in procedure AP/0/A/5500/44, Plant Flooding, to determine whether the desired results could be achieved.

Enclosure b.

Findings No findings of significance were identified.

1R11 Licensed Operator Requalification a.

Inspection Scope On August 2, the inspectors observed licensed operator performance during requalification simulator training for shift E, to determine whether operator performance was consistent with expected operator performance, as described in Exercise Guide OP-MC-SRT-071. This training tested the operators ability to perform abnormal and emergency procedures dealing with reactor trip, safety injection, loss of coolant, loss of high pressure and safety injection flows, and plant cooldown and depressurization. The inspectors focused on clarity and formality of communication, use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. The inspectors observed the post-exercise critique to determine whether the licensee identified deficiencies and discrepancies that occurred during the simulator training.

The inspectors reviewed the following PIP associated with this area, to determine whether the licensee identified and implemented appropriate corrective actions:

PIP M-06-0675, New Time Critical Actions For Operators Identified by Risk Analysis

b.

Findings No findings of significance were identified.

1R12 Maintenance Effectiveness a.

Inspection Scope The inspectors reviewed the two maintenance-related items listed below for such attributes as: (1) appropriate work practices; (2) identifying and addressing common cause failures; (3) scoping in accordance with 10 CFR 50.65(b) of the maintenance rule (MR); (4) characterizing reliability issues for performance; (5) trending key parameters for condition monitoring; (6) charging unavailability for performance; (7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and (8) the appropriateness of performance criteria for SSCs/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). Documents reviewed are listed in the Attachment to this report.

Items reviewed were:

Emergency Diesel Generator Run/Shutdown Solenoid Valve unavailability due to improperly sized diodes

Charging Pump unavailability due to improperly aligned oil cooler end bells

Enclosure b.

Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation a.

Inspection Scope The inspectors reviewed the licensees risk assessments and the risk management actions used to manage risk for the plant configurations associated with the five activities listed below. The inspectors assessed whether the licensee performed adequate risk assessments and implemented appropriate risk management actions when required by 10CFR50.65(a)(4). For emergent work, the inspectors determined whether any increase in risk was promptly assessed and if appropriate risk management actions were promptly implemented. The inspectors also reviewed associated PIPs to determine whether the licensee identified and implemented appropriate corrective actions.

• Week of July 9, including emergent work associated with Unit 2 channel 1 refueling water storage tank level instrument failing low due to electromagnetic interference from relays associated with the test/normal switch of channel 2 level instrument.

• Week of July 16, including emergent work associated with the automatic shutdown of the 1B EDG (during surveillance testing) due to an erroneous signal from a failed fire detector.

• Week of July 23, including emergent work associated with 1B1 component cooling water (KC) pump slinger ring failure after routine startup.

• Week of August 6, including emergent work associated with restoring manual strainer backwash function of the Unit 1 and 2 nuclear service water systems and associated contingency actions to manage risk.

• Week of August 13, including emergent work to replace the failed Unit 1 turbine driven auxiliary feedwater pump governor control.

• Week of September 17, including emergent work to replace the failed 1A1 KC pump discharge check valve.

• Week of September 24, including emergent work to ensure the containment air purge sample line isolation valves stroked fully shut after a failed valve stroke timing test.

b.

Findings No findings of significance were identified.

1R15 Operability Evaluation a.

Inspection Scope The inspectors reviewed the operability determinations the licensee had generated that warranted selection on the basis of risk insights. The inspectors assessed the accuracy

Enclosure of the evaluations, the use and control of any necessary compensatory measures, and compliance with the Technical Specifications (TS). The inspectors determined whether the operability determinations were made as specified by Nuclear System Directive (NSD) 203, Operability. The inspectors compared the arguments made in the determination to the requirements from the TS, the UFSAR, and associated design-basis documents, to determine whether operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred. The selected samples are addressed in the PIPs listed below:

M-07-3533, Cables not properly secured to electray

M-07-1945, Piping analysis review discovered inappropriate use of code cases N-397 and N-411 in calculations MCC-1206.02-74-0028 and NCC-1206.02-84-0018

M-07-0840, Non-conservative TS associated with Pressurizer Water Level - High

M-07-0841, Non-conservative TS associated with reactor coolant pump under frequency

M-07-0365, Non-destructive examination (NDE) results for containment spray piping for both units

M-07-4313, Inability to manually backwash nuclear service water pump strainers post-accident The inspectors reviewed PIP M-02-2830, Westinghouse Analysis WCAP-8110 Supplement 9 is not applicable to UFSAR, to determine how the licensee had resolved this issue. The inspectors reviewed the TS and bases, the UFSAR, the associated design-basis document, and UFSAR change package 02-028 to determine the adequacy of the licensees corrective actions.

b.

Findings Introduction: The inspectors identified a severity level IV non-cited violation (NCV) of 10 CFR 50.59 for failing to perform a written safety evaluation for a change to the facility as described in the Updated Final Safety Analysis Report (UFSAR).

Description: While conducting a review of PIP M-02-2830 (Removal of WCAP-8110 Supplement 9 reference in UFSAR) on September 17, 2007, the inspectors found that the licensing basis for seismically qualifying the ice contained in the ice condenser had been completely removed from the UFSAR. The inspectors concluded that this removal constituted a change to the facility. The licensing basis, Westinghouse analysis WCAP-8110 Supplement 9, had been removed from UFSAR sections 1.6.1 and 6.2.8 as part of UFSAR change package 02-028. The licensee was unable to provide any evaluation conducted under 10 CFR 50.59 for this licensing basis change.

The inspectors reviewed a November 21, 1974, NRC Safety Evaluation Report (SER) for WCAP-8110 Supplement 9, which stated the WCAP is considered an accepted methodology to demonstrate the continued adequacy of ice retention characteristics of the ice baskets when used as a reference for license applications. As stated in the SER, WCAP-8110 Supplement 9 described that, based on test data, newly added ice inside the ice condenser should have a minimum time of 5 weeks to fuse prior to power

Enclosure ascension to ensure acceptable seismically qualified ice retention inside the ice condensers should a design basis earthquake (DBE) occur. Without allowing proper fusion time, the ice could fall to the bottom of the condenser during a DBE and make the ice condenser incapable of performing its intended safety function. The WCAP testing vibrated ice baskets, simulating the DBE time histories for Duke Power Company. The SER concluded that the data presented in the WCAP was adequate to conclude that land-based plants using ice condenser type containments should begin their initial ascent to power after a minimum of five weeks following ice loading.

Analysis: The failure to perform a written safety evaluation for changes made to the facility as described in the UFSAR is more than minor because there was a reasonable likelihood that the change requiring a 10 CFR 50.59 written safety evaluation would require Commission review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2). This likelihood is based on the November 21, 1974, NRC Safety Evaluation Report for WCAP-8110 Supplement 9, which stated the WCAP is considered an accepted methodology to demonstrate the continued adequacy of ice retention characteristics of the ice baskets when used as a reference for license applications.

Removal of this approved methodology from the licensing basis would constitute a change in methodology and would require NRC review and approval. This issue was treated as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. It was characterized as a Severity Level IV violation because it was evaluated as not having greater than very low safety significance.

Enforcement: 10 CFR 50.59(c)(1) states that a licensee may make changes in the facility as described in the Final Safety Analysis Report (as updated), without obtaining a license amendment pursuant to 50.90 only if the change does not meet any of the criteria in paragraph 10 CFR 50.59(c)(2). 10 CFR 50.59(d)(1) states that the licensee shall maintain records of changes in the facility as described in the UFSAR. These records must include a written safety evaluation which provides the bases for the determination that the change does not require a license amendment pursuant to paragraph (c)(2) of this section. Contrary to the above, in 2002, the licensee failed to perform a written safety evaluation prior to making a change to the facility as described in the UFSAR. Specifically, they removed reference to WCAP-8110 Supplement 9 analysis from UFSAR sections 1.6.1 and 6.2.8. The WCAP provided the bases for seismic qualification for ice retention inside the ice condensers. The failure to perform a written safety evaluation was characterized as a severity level IV violation. This issue is in the licensees corrective action program as PIP M-07-5016. Consequently, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000369,370/2007004-01, Failure to Perform a Written Safety Evaluation for a Change to the Facility.

1R19 Post Maintenance Testing a.

Inspection Scope The inspectors reviewed the five post-maintenance tests listed below to determine whether procedures and test activities ensured system operability and functional

Enclosure capability. The inspectors reviewed the licensees test procedure to determine whether the procedure adequately tested the safety function(s) that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed the test data, to determine whether test results adequately demonstrated restoration of the affected safety function(s).

• PT/1/A/4209/001 A, 1A Charging Pump Performance Test (after replacing motor coolant supply valve 1RN-103A)

PT/1/A/4208/001 A, 1A Containment Spray Pump Performance Test (after replacing pump suction vent valve 1NS-91A)

PT/2/A/4201/001 A, Refueling Water Storage Tank (RWST) Level Auto Switchover Analog Channel Operational Test (after replacement of test/normal switch)

PT/1/A/4350/002 A, Diesel Generator 1A Operability Test (after replacing the fuel oil transfer pump and run/shutdown solenoid diodes)

PT/1/A/4252/012 C, Unit 1 Turbine Driven CA Pump Head Curve Test (after replacing the governor assembly)

b.

Findings No findings of significance were identified.

1R22 Surveillance Testing a.

Inspection Scope For the surveillance tests identified below, the inspectors witnessed testing and/or reviewed the test data to assess whether the tests demonstrated that the SSCs were capable of performing their intended safety functions, as well as determine whether the SSCs involved in these tests satisfied the requirements described in the TSs, the UFSAR, and applicable licensee procedures.

• PT/0/1/4601/008A, SSPS Train A Periodic Test With NC System Pressure > 1955 psig

• PT/1/A/4252/001A, 1A Auxiliary Feedwater Pump Performance Test

• PT/2/A/4252/001C, #2 Turbine-Driven CA Pump Performance Test Opening 2SA-49 First

PT/1/A/4150/001B, Reactor Coolant Leakage Calculation

PT/2/A/4150/001B, Reactor Coolant Leakage Calculation

PT/0/A/4350/040, 125 VDC Vital I and C Battery Performance Test

PT/1/A/4600/014, NIS Power Range N-41 Analog Channel Operational Test

• (Note: This procedure included in-service testing requirements.)

The inspectors reviewed the associated PIP listed below to determine whether the licensee identified and implemented appropriate corrective actions:

Enclosure

M-07-3870, New Enclosure 13.5 of PT/2/A/4150/001B could not be implemented as written b.

Findings No findings of significance were identified.

1R23 Temporary Plant Modifications a.

Inspection Scope The inspectors reviewed the four temporary modifications listed below and the associated 10 CFR 50.59 screening to determine whether the modifications satisfied the requirements of 10CFR50, Appendix B, Criterion III, Design Control. Each modification was compared against the UFSAR and TS to determine whether it affected operability or availability of the associated system. The inspectors walked down each modification to ensure that it was installed in accordance with the modification documents. Post-installation and removal testing was also reviewed to determine whether the actual impact on permanent systems was adequately verified by the tests. All four temporary modifications were associated with reestablishing safety-related manual backwash capabilities for the Unit 1 and 2 nuclear service water systems.

• MD101360, Modify valves 1RN-22 and 1RN-23

MD101361, Modify valves 1RN-26 and 1RN-27

MD201362, Modify valves 2RN-22 and 2RN-23

MD201363, Modify valves 2RN-26 and 2RN-27 b.

Findings No findings of significance were identified.

Cornerstone: Emergency Preparedness 1EP6 Drill Evaluation a.

Inspection Scope The resident inspectors evaluated the conduct of a routine licensee emergency drill on August 29, 2007, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation (PAR) development activities in accordance with 10CFR50, Appendix E. The inspectors observed emergency response operations in the simulator control room and technical support center to assess the overall response of the personnel involved in the drill from an operations and emergency planning perspective. The inspectors evaluated whether event classification and notifications were done in accordance with RP/000, Classification of Emergency. The inspectors also attended the licensees critique of the drill to compare any inspector-observed weakness with those identified by the licensee in order to determine whether the licensee was properly identifying problems.

Enclosure b.

Findings No findings of significance were identified.

4.

OTHER ACTIVITIES 4OA1 Performance Indicator Verification a.

Inspection Scope For the performance indicators (PIs) listed below, the inspectors sampled licensee PI data for the period from April 2006 through August 2007. To verify the accuracy of the PI data reported during that period, the inspectors compared the licensees basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline.

Mitigating Systems Cornerstone

Safety System Functional Failures (Units 1 and 2)

The inspectors reviewed Licensee Event Reports (LERs) and Maintenance Rule records, to determine whether the licensee had adequately accounted for functional failures that the subject systems had experienced for the period from April 2006 through August 2007.

Barrier Integrity Cornerstone

Reactor Coolant System Specific Activity (Units 1 and 2)

The inspectors reviewed licensee sampling and analysis of reactor coolant system samples from April 2006 through August 2007, and compared the licensee-reported performance indicator data with records developed by the licensee while analyzing previous samples.

• Reactor Coolant System Leak Rate Performance Indicator (Units 1 and 2)

The inspectors reviewed surveillance test records of measured reactor coolant system identified leakage from April 2006 through August 2007.

b.

Findings No findings of significance were identified.

Enclosure 4OA2 Problem Identification and Resolution

.1 Daily Screening of Corrective Action Items As required by Inspection Procedure 71152, "Identification and Resolution of Problems", and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by reviewing hard copies of condition reports, attending daily screening meetings, and accessing the licensees computerized database.

.2 Annual Sample Review a.

Inspection Scope The inspectors selected PIPs M-04-1294, M-05-4023, M-06-0799, and M-07-0365 for detailed review. These PIPs were associated with leakage found in the Unit 1 and Unit 2 containment spray headers located in the reactor building annulus. The inspectors reviewed these reports to determine whether the licensee identified the full extent of the issue, performed an appropriate evaluation, and specified/prioritized appropriate corrective actions. The inspectors evaluated the report against the requirements of the licensees corrective action program as delineated in corporate procedure NSD 208, Problem Identification Process, and 10 CFR 50, Appendix B.

The inspectors performed a review of the 15 priority 1-3 operator workarounds (OWAs)

listed in the licensees July 2007 OWA report to determine whether the OWAs were identified in the corrective action program, and whether corrective actions have been properly identified and dates established for completion. The inspectors reviewed the individual and cumulative effect of the these OWAs on the Emergency and Abnormal Operating Procedures. In some cases the review included the PIPs associated with the OWA and a review of the system health report for the associated system. In addition, the four priority 4 OWAs (licensee intends to take no action) were reviewed to ensure that they should not be rated higher. A review of selected workarounds closed in the last 2 years was conducted to determine whether the closed OWAs were corrected.

b.

Observations and Findings No findings of significance were identified.

4OA3 Event Follow-up (Closed) LER 05000369/2007003, Inoperable Source Range Neutron Flux Monitors During Mode 6 and Core Alterations. The licensee attributed this failure to not including the Gamma-Metrics shutdown monitor requirements in surveillance and operating procedures when these source range monitors were credited in TSs as redundant monitors. The licensees corrective actions included revising procedures to adequately define operability requirements for the monitors, as well as revising the computer based

Enclosure TS tracking log with these requirements. The licensee had not completed the corrective actions at the time of this review.

The inspectors review revealed that one source range monitor was fully operable and was being relied upon for visible and audible count rate indication, and high flux at shutdown alarm functions. The second source range monitor was inoperable for high flux at shutdown alarm adjustment. The third and fourth source range monitors (Gamma-Metrics) were providing visible count rate indication and were being monitored, but were found to have the audible high flux at shutdown alarm bypassed.

With the switch in the normal position, the alarm function would have worked. The failure to have an operable high flux at shutdown alarm for an additional source range monitor constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section IV of the NRCs Enforcement Policy. This LER is closed.

4OA5 Other Activities Operation of Independent Spent Fuel Storage Installation (ISFSI)

a.

Inspection Scope The inspectors reviewed changes made to ISFSI programs and procedures since the last inspection to determine whether the changes made were consistent with the license or Certificate of Compliance (CoC) and did not reduce the effectiveness of the program. The inspectors also inspected the procedures to determine whether they still fulfilled the commitments and requirements specified in the Safety Analysis Report, CoC, the site-specific license and TSs, any related 10 CFR 50.59 and 72.48 evaluations, and 10 CFR 72.212(b) written evaluations for general licensed ISFSIs.

The inspectors reviewed the evaluations performed pursuant to 10 CFR 72.48 since September 2006, for the ISFSI TN-32 and NAC-UMS storage casks. The inspectors also reviewed PIP M-06-3729, which identified a failure to perform 10 CFR 72.48 evaluations for previous revisions to 10 CFR 72.212 written evaluations (NCV 05000369,370/2006004-04) to determine if the corrective actions were effective.

b.

Findings Introduction: The inspectors identified a severity level IV violation of 10 CFR 72.172 for failing to promptly identify and correct a condition adverse to quality associated with not performing 10 CFR 72.48(c) evaluations on five previous revisions of 10 CFR 72.212(b)(2) written evaluations for the ISFSI.

Description: While conducting the annual ISFSI inspection on August 2, 2007, the inspectors reviewed PIP M-06-3729, which is associated with NCV 05000369,370/

2006004-04. It was determined that the failure to perform 10 CFR 72.48(c) evaluations on five previous revisions of 10 CFR 72.212(b)(2) from the last annual ISFSI inspection had still not been corrected. The inspectors discussed this issue with the licensee

Enclosure management, who initiated PIP M-07-4321 and promptly completed the delinquent 10 CFR 72.48(c) evaluations.

Analysis: The failure to promptly correct and perform the 10 CFR 72.48(c) evaluations for changes to 72.212(b)(2) written evaluations is important because the 10 CFR 72.48(c) evaluation determines whether prior NRC approval is needed before a change can be implemented to the facility or spent fuel storage cask design. This issue is greater than minor because the failure to promptly correct and perform 10 CFR 72.48(c)

evaluations on any changes to 10 CFR 72.212(b)(2) written evaluations had a reasonable likelihood that the changes could require NRC review and approval. This issue was considered as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. It was characterized as a severity level IV violation because it was evaluated as not having greater than very low safety significance. This finding has a cross-cutting aspect of timely corrective action in the area of problem identification and resolution (P.1.d).

Enforcement: 10 CFR 72.172 requires that the licensee shall promptly identify and correct any conditions adverse to quality. Contrary to the above, prior to August 2, 2007, the licensee failed to promptly correct a condition adverse to quality in that they failed to take any corrective action for a 10 CFR 72.212 violation identified during the previous annual ISFSI inspection. The failure to correct this condition promptly was considered a violation and is characterized as a severity level IV violation. This issue is in the licensees corrective action program as PIP M-07-4321. Consequently, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000369,370/2007004-02: Failure to Promptly Correct a Condition Adverse to Quality.

4OA6 Meetings, Including Exit On October 4, 2007, the resident inspectors presented the inspection results to Mr. and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Ashe, K., Manager, Regulatory Compliance Black, D., Security Manager Bradshaw, S., Training Manager Brown, S., Manager, Engineering Crane, K., Regulatory Compliance Evans, K., Superintendent, Maintenance Hull, P., Chemistry Manager Kammer, J., Manager, Safety Assurance Mooneyhan, S., Radiation Protection Manager Nolin, J., Manager, Mechanical and Civil Engineering Parker, R., Superintendent, Work Control Peterson, G., Site Vice President, McGuire Nuclear Station Repko, R., Station Manager, McGuire Nuclear Station Simril, T., Superintendent, Plant Operations Snider, S., Manager, Reactor and Electrical Systems Engineering NRC personnel J. Moorman, III, Chief, Reactor Projects Branch 1 J. Stang, Project Manager, NRR LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 0500369,370/2007004-01 NCV Failure to Perform a Written Safety Evaluation fora Change to the Facility (Section 1R15)

0500369,370/2007004-02 NCV Failure to Promptly Correct a Condition Adverse to Quality (Section 4OA5)

Closed 0500369/2007003 LER Inoperable Source Range Neutron Flux Monitors During Mode 6 and Core Alterations (Section 4OA3)

Attachment LIST OF DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection

[Impending]

RP/0/A/5700/006, Natural Disasters

[Seasonal]

PT/0/B/4700/039, Warm Weather Equipment Checkout, dated 4/1/07 Licensees Hot Weather Computer Spreadsheet for 2007 Licensees Hot Weather Action Item Register for 2007 PIP-M-07-4317, Unit 1 6900 Volt Switchgear Room Elevated Temperature PIP-M-07-4420, Unit 2 Turbine Generator Hydrogen Cooler High Temperature PIP-M-07-4464, Unit 1 and 2 Ice Condenser Chiller Elevated Temperatures Section 1R04: Equipment Alignment Chemical and Volume Control System 1B Drawing MCFD-1554-01.00, Flow Diagram of the Chemical and Volume Control System Drawing MCFD-1554-02.00, Flow Diagram of the Chemical and Volume Control System Drawing MCFD-1554-03.00, Flow Diagram of the Chemical and Volume Control System Containment Spray System 1B Drawing MCFD-1563-01.00, Flow Diagram of the Containment Spray System Emergency Diesel Generator 2A Drawing MCFD-2609-04.00, Flow Diagram of the Diesel Generator Starting Air System Drawing MCFD-2609-03.00, Flow Diagram of the Diesel Generator Engine 2A Fuel Oil System Drawing MCFD-2609-02.00, Flow Diagram of the Diesel Generator Engine Lube Oil System Drawing MCFD-2609-01.00, Flow Diagram of the Diesel Generator Engine Cooling Water System Auxiliary Feedwater System 2A Drawing MCFD-2592-01.01, Flow Diagram of Auxiliary Feedwater System Drawing MCFD-2592-02.00, Flow Diagram of Auxiliary Feedwater System OP/2/A/6250/002, Auxiliary Feedwater System, Rev. 72, Enclosure 4.8, Valve and Power Checklist Section 1R05: Fire Protection Procedures McGuire Nuclear Station IPEEE Submittal Report dated June 1, 1994 McGuire Nuclear Station Supplemental IPEEE Fire Analysis Report dated August 1, 1996 MCS-1465.00-00-0008, R4, Design Basis Specification for Fire Protection

Attachment Section 1R06: Flood Protection Measures

[External Flooding]

UFSAR Sections 2.4.10, Flooding Protection Requirements 2.4.13.5, Design Bases for Subsurface Hydrostatic Loading 3.4, Water Level (Flood) Design Design Basis Documents MCS-1465.00-00-0012, Design Basis Specification for Flooding From External Sources, Rev 1 MCS-1154.00-00-004, Design Basis Specification for the Auxiliary Building Structures, section 2.3.13 and 3.2.1.3.3.4, external flooding MCS-1581.WZ-00-0001, Design Basis Specification for the WZ System Calculations:

MCC-1223.42-00-0037, Evaluation of the Use of Non-Safety Water Sources for the Auxiliary Feedwater System, Sec. 10.8, Rev. 6 Work Orders 98663476 98664573 PIPs M-04-3765 M-03-1377 M-05-3040 M-06-3715 Other Documents:

Selected Licensee Commitment 16.9.8, Ground Water Level Monitoring System IN 2003-08, Potential Flooding through unsealed concrete floor cracks IN 83-44, Potential damage to redundant safety equipment as a result of backflow through the equipment and floor drain system IN 94-27, Facility Operating Concerns Resulting From Local Area Flooding IN 92-69, Water leakage from yard area through conduits into buildings IN-87-49, Deficiencies in Outside Containment Flooding Protection Drawing MCFD-1581-01.00, Flow Diagram of Groundwater Drainage System Cowans Ford Development 8th Five-Year Safety Inspection Report, December 2002

[Internal Flooding]

UFSAR Sections 9.3.3, Equipment and Floor Drainage System 2.4.13.5, Design Bases for Subsurface Hydrostatic Loading

Attachment Attachment Design Basis Documents MCS-1154.00-00-004, Design Basis Specification for the Auxiliary Building Structures, section 30.2.1.3.4.1, Internal Flooding Calculations MCC-1139.01-00-0268, Turbine Building and Auxiliary Building, Sec. 10.8, Rev. 6 MCC-1206.47-69-1001, Auxiliary Building Flooding Analysis, Sec.9.2-9.2.1, Rev. 11 Procedures AP/0/A/5500/44, Plant Flooding, Rev. 3 IP/0/A/3215/004, Magnetrol Liquid Level Control Switch Calibration, Rev. 15 IP/0/A/3215/002, Robertshaw SL-400 series Level AC - Liquid Level Controller Calibration IP/0/A/3050/017D, ND and NS Pump Room Level Calibration PT/0/A/4973/007 A,B,C; WZ Sump Pump Performance Tests OP/1/A/6100/010 Annunciator Response Computer alarm response for points M1P5062 and M2P5063 Work Orders 98753832, U1 diesel generator penetration seals PMIDs 11720 through 11726, clean sump and test pump PIPs C-06-7420 M-06-2070 M-07-0816 Other Documents:

IN 2005-11, Internal Flooding/ Spray Down of Safety Related Equipment Due to Unsealed Equipment Hatch Floor Plugs and/or Blocked Drains IN 2003-08, Potential Flooding Through Unsealed Concrete Floor Cracks Section1R11: Licensed Operator Requalification MTP 2701.0, Simulator Configuration Management and Operating Limits, Revision 3 Nuclear Policy Manual, Nuclear System Directive 512, Maintenance of RO/SRO NRC Licenses, Revision 1 Exercise Guide OP-MC-SRT-071 Section1R12: Maintenance Effectiveness M-07-4200, Incorrect Diodes Installed on Emergency Diesel Generator Run/Shutdown Solenoid Valves M-07-4758, Oil Coolers End Cover Previously Installed Incorrectly NRC IR 05000369,370/2007009, SIT

Attachment Section 1R23: Temporary Plant Modifications PIP M-07-4313 UFSAR section 7.8.2 Associated 10CFR 50.59 screening forms MCS-1574.RN-00-0001, Design Basis Specification for RN system Section 1EP6: Drill Evaluation RP/0/A/5700/000; Classification of an Emergency RP/0/A/5700/001; Notification of an Unusual Event RP/0/A/5700/002; Notification of an Alert RP/0/A/5700/003; Site Area Emergency RP/0/A/5700/029; Notifications to Offsite Agencies from the Control Room Section 4OA3: Event Follow-up LER 2007-003 PIPs M-07-2486, M-07-4249 UFSAR sections 4 and 7 10CFR50.59 evaluation for MCC-1503-00-0500 TS 3.9.3 and bases Section 4OA5: Other MP/0/A/7650/188, R17, Operation of Dry Cask Transporter MP/0/A/7650/212, R12, Loading Spent Fuel Assemblies into NAC-UMS Casks MP/0/A/7650/204, R 4, Spent Fuel Dry Storage Cask Troubleshooting OP/0/A/6550/028, R 3, NAC-UMS Fuel Assembly Loading/Unloading

LIST OF ACRONYMS AB

-

Auxiliary Building ACOT

-

Analog Channel Operational Test CA

-

Auxiliary Feedwater CAST

-

Auxiliary Feedwater Storage Tank CoC

-

Certificate of Compliance DBE

-

Design Bases Earthquake EDG

-

Emergency Diesel Generator FSAR

-

Final Safety Analysis Report ISFSI

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Independent Spent Fuel Storage Installation INPO

-

Institute of Nuclear Power Operation KC

-

Component Cooling Water LER

-

Licensee Event Report

Attachment Attachment MR

-

Maintenance Rule NC

-

Reactor Coolant NCV

-

Non-Cited Violation NDE

-

Non-Destructive Examination NRC

-

Nuclear Regulatory Commission NS

-

Containment Spray NSD

-

Nuclear System Directive NV

-

Chemical and Volume Control OWA

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Operator Workaround PAR

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Protective Action Recommendation PARS

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Publicly Available Records PI

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Performance Indicator PIP

-

Problem Investigation Process report PSIG

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Pounds per sq. in. Gauge RTP

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Rated Thermal Power SER

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Safety Evaluation Report SSC

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Structures, Systems, Components TS

-

Technical Specifications UFSAR

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Updated Final Safety Analysis Report