IR 05000324/2012002

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IR 05000325-12-002, 05000324-12-002, 05000325-12-501, 05000324-12-501, on 01/01/12 -03/31/12, Brunswick Steam Electric Plant, Units 1 & 2, Follow-up of Events
ML12121A014
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 04/26/2012
From: Randy Musser
NRC/RGN-II/DRP/RPB4
To: Annacone M
Carolina Power & Light Co
Catherine Morrison
References
IR-12-002, IR-12-501
Download: ML12121A014 (49)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 26, 2012

Mr. Michael Annacone Vice President Carolina Power and Light Company Brunswick Steam Electric Plant P.O. Box 10429 Southport, NC 28461

SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT NOS.: 05000325/2012002, 05000324/2012002, 05000325/2012501 AND 05000324/2012501

Dear Mr. Annacone:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed integrated inspection report documents the inspection findings, which were discussed on April 20, 2012, with you and other members of your staff.

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

One self-revealing finding of very low safety significance (Green) was identified during this inspection. This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Brunswick Steam Electric Plant.

If you disagree with the cross-cutting aspect of the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Brunswick Steam Electric Plant.

CP&L 2 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/

Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62

Enclosure:

Inspection Report 05000325, 324/2012002, 05000325/2012501, 05000324/2012501 w/Attachment: Supplemental Information

REGION II==

Docket Nos. 50-325, 50-324 License Nos. DPR-71, DPR-62 Report Nos. 05000325/2012002, 05000324/2012002, 05000325/2012501, 05000324/2012501 Licensee: Carolina Power and Light (CP&L)

Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: 8470 River Road, SE Southport, NC 28461 Dates: January 1, 2012 through March 31, 2012 Inspectors: P. O'Bryan, Senior Resident Inspector M. Schwieg, Resident Inspector D. Meléndez-Coln, Acting Senior Resident Inspector A. Sengupta, Reactor Inspector (Section 1R08) S. Sanchez, Senior Resident Inspector (Section 1R19, 1R22) J. Nadel, Resident Inspector (Section 1R05, 1R11, 4OA5)

A. Guzzetta, Reactor Inspector - Intern G. Kuzo, Senior Health Physicist (Section 2RS6, 4OA1) W. Loo, Senior Health Physicist (Section 2RS1, 4OA5) A. Nielsen, Senior Health Physicist (Section 2RS6, 2RS7) W. Pursley, Health Physicist (Section 2RS1, 2RS8) J. Worosilo, Project Engineer (Section 1R06, 1R20)

Approved by: Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000325/2012002, 05000324/2012002, 05000325/2012501, 05000324/2012501; 01/01/12 -03/31/12; Brunswick Steam Electric Plant, Units 1 & 2; Follow-up of Events.

This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One self-revealing Green finding was identified by the inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspects were determined using IMC 0310, "Components Within the Cross-Cutting Areas". Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Barrier Integrity

Green.

A self-revealing non-cited violation of 10 CFR 50 Appendix B, Criteria XVI, Corrective Action, was identified for the licensee's failure to promptly identify and correct a condition adverse to quality related to the Control Room Air Conditioning (AC) system and the Control Room Emergency Ventilation (CREV) system. Specifically, the licensee failed to identify and correct a slow refrigerant leak in the instrument air dryer in the control building HVAC instrument air system, rendering both the control room AC and CREV systems inoperable. Upon discovery, the instrument air dryer was bypassed, air pressure was restored, and the control room AC and CREV systems were restored. The licensee entered this issue into the corrective action program as Action Request (AR)502214.

The failure to identify and correct the slowly lowering refrigerant pressure was a performance deficiency. This finding was more than minor because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone. It also adversely affected the cornerstone objective of maintaining a radiological barrier for the control room. Specifically, the finding led to a loss of all air conditioning and filtering capability of control room air. The significance determination process was completed in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Barrier Integrity Cornerstone. The finding was determined to be of very low safety significance (Green) because it only affected the radiological barrier function of the control room, and does not represent a degradation of the smoke or toxic atmosphere barrier function of the control room. This finding has a cross-cutting aspect in the corrective action program component of the Problem Identification and Resolution area because the licensee did not identify the issue completely, accurately, and in a timely manner commensurate with its safety significance. [P.1 (a)] (Section 4OA3)

B. Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at rated thermal power (RTP), and operated at or near full power until January 29, 2012, when control rod 18-35 malfunctioned and was individually scrammed. Reactor power after the rod scram was 80 percent and power was returned to approximately 95 percent the same day. Reactor power coasted from 95 percent to approximately 83 percent on February 22, 2012. On February 22, 2012, the reactor was scrammed due to a loss of main condenser circulating water resulting from a failed electric bus transformer. The unit entered a refueling outage and remained shut down for the remainder of the quarter.

Unit 2 began the inspection period at RTP. On February 2, 2012, reactor power was reduced to approximately 39 percent due to an inadvertent runback of the 2A recirculation pump. From February 3, 2012 to February 6, 2012, reactor power was increased and returned to RTP. On February 22, 2012, reactor power was reduced to approximately 95 percent due to a failed electric bus transformer and reactor power was returned to RTP on February 23, 2012. Reactor power remained at or near RTP for the remainder of the quarter.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed four (4)partial system walkdowns of the following risk-significant systems:

  • The A loop of the Unit 2 residual heat removal system with the B loop out of service for planned maintenance on January 6, 2012;
  • The A train of the Unit 1 core spray system with the B train out of service for planned maintenance on February 3, 2012;
  • The Unit 1 conventional service water system with the nuclear service water system out of service for planned maintenance on March 6 and March 7, 2012; and

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), Technical Specification (TS) requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify that system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system alignment inspection of the Unit 1 reactor building closed cooling water (RBCCW) system to verify the functional capability of the system. This system was selected because it was considered risk-significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line-ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders (WOs)was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment alignment problems were being identified and appropriately resolved.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Resident Inspector Tours

a. Inspection Scope

The inspectors conducted six (6)fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

  • Unit 1 Cable Spreading Room and Battery Rooms 1PFP-CB-5;
  • Unit 2 Cable Spreading Room and Battery Rooms 2PFP-CB-6;
  • Diesel Generator Cells 1 through 4, 23' Elevation 1-PFP-DG-2,3,4,5;
  • Main Control Room; and
  • E1-E4 Switchgear Rooms, 50' Elevation of EDG building 1PFP-DG-11, 12, 13, 14.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On February 7, 2012, the inspectors observed fire brigade performance during an announced fire drill. The observation was used to determine the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective action. 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 firefighting 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.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Review of Areas Susceptible To Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk-important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including UFSAR, engineering calculations, and abnormal operating procedures (AOPs), for licensee commitments. The specific documents reviewed are listed in the Attachment. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensee's corrective action documents with respect to past flood-related items identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area(s) to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

b. Findings

No findings were identified.

.2 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of one

(1) underground manhole subject to flooding that contains cables whose failure could disable risk-significant equipment. The inspectors performed walkdowns of risk-significant areas containing manhole 2-MH-6SW, to verify that the cables were not submerged in water, that cables and/or splices appear intact and to observe the condition of cable support structures. The inspectors ensured that drainage was provided and was functioning properly.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensee's testing of the Unit 1 B train residual heat removal heat exchanger to verify that potential deficiencies did not mask the licensee's ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensee's observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also visually inspected the service water side of the heat exchanger to ensure that the heat exchanger was free of debris and biological growth.

b. Findings

No findings were identified.

1R08 In-service Inspection Activities

.1 Non-Destructive Examination Activities and Welding Activities

a. Inspection Scope

Non-Destructive Examination Activities and Welding Activities: From March 12, 2012, through March 16, 2012, the inspectors conducted a review of the implementation of the licensee's In-service Inspection (ISI) Program for monitoring degradation of the reactor coolant system, emergency feedwater systems, risk-significant piping and components, and containment systems. The inspectors reviewed the implementation of the licensee's Risk Informed In-service Inspection (ISI) program for monitoring degradation of the reactor coolant system (RCS) boundary and risk significant piping boundaries. The inspectors activities consisted of an on-site review of non-destructive examination (NDE) and welding activities to evaluate compliance with the applicable edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),Section XI (Code of record: 2001 Edition through 2003 Addendum) and that indications and defects (if present) were appropriately evaluated, and dispositioned in accordance with the requirements of the ASME Code,Section XI acceptance standards or NRC approved alternative requirement. The inspectors directly observed or reviewed records of the following NDE mandated by the ASME Code to evaluate compliance with ASME Code Section XI and Section V requirements, and ascertain any indications of defects. Inspectors also reviewed evaluations of results that were dispositioned in accordance with the ASME Code or an NRC-approved alternative requirement.

(1) Directly observed:
(2) Reviewed records:
  • RT examination of RCIC Injection Line (Work Order 01531102-08) of line # 1-E51-3-4-901 During non-destructive surface and volumetric examinations performed since the previous refueling outage, the licensee did not identify any recordable indications that required acceptance for continued service. Therefore, no NRC review was required for this inspection procedure attribute.

The inspectors reviewed documentation for the repair/replacement of the following pressure boundary welds. The inspectors evaluated if the licensee applied the pre-service non-destructive examinations and acceptance criteria required by the Construction Code. In addition, the inspectors reviewed the welding procedure specifications, welder qualifications, welding material certifications, and supporting weld procedure qualification records to evaluate if the weld procedures were qualified in accordance with the requirements of the Construction Code and the ASME Code Section IX.

Vessel Upper Head Penetration (VUHP) Inspection Activities Not applicable for BWRs, PWRs only.

Boric Acid Corrosion Control (BACC) Inspection Activities Not applicable for BWRs, PWRs only.

Steam Generator (SG) Tube Inspection Activities BWR reactor plants do not have steam generators, therefore, this is not applicable for BWRs. Identification and Resolution of Problems The inspectors performed a review of ISI-related problems, including welding, that were identified by the licensee and entered into the corrective action program as a Condition Report (CR). The inspectors reviewed the CRs to confirm that the licensee had appropriately described the scope of the problem and then evaluated and identified appropriate corrective actions. The review also included the review of the licensee's use, 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 Performance

.1 Licensed Operator Requalification and Continuing Training

a. Inspection Scope

On February 8, 2012, the inspectors observed a crew of licensed operators in the plant's simulator during a licensed operator training scenario to verify that operator performance was adequate and evaluators were identifying and documenting crew performance problems, and to ensure that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

  • licensed operator performance;
  • crew's clarity and formality of communications;
  • ability to take timely actions in the conservative direction;
  • prioritization, interpretation, and verification of annunciator alarms;
  • correct use and implementation of abnormal and emergency procedures;
  • control board manipulations;
  • oversight and direction from supervisors; and
  • ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.

b. Findings

No findings were identified.

.2 Main Control Room Operator Performance

a. Inspection Scope

On February 23, 2012, the inspectors observed operators in the plant's main control room during response to a reactor scram and loss of electrical bus Common C to verify that operator performance was adequate. The inspectors evaluated the following areas:

  • operator compliance and use of plant procedures, including procedure entry and exit, performing procedure steps in the proper sequence, procedure place-keeping, and technical specification entry and exit;
  • control board/in-plant component manipulations;
  • communications between crew members;
  • use and interpretation of plant instruments, indications, and alarms; diagnosis of plant conditions based on instruments, indications, and alarms;
  • use of human error prevention techniques, such as pre-job briefs and peer checking;
  • documentation of activities, including initials and sign-offs in procedures, control room logs, technical specification entry and exit, entry into out-of-service logs;
  • management and supervision of activities, including risk management and reactivity management; and
  • crew briefs.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated two (2)degraded performance issues involving the following risk-significant systems:

  • Failed control switch relay for the Unit 2 wet well vent line, CS-4179 (AR 513817513817.

The inspectors reviewed events where ineffective equipment maintenance may have resulted in equipment failure or invalid automatic actuations of Engineered Safeguards Systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

  • implementing appropriate work practices;
  • identifying and addressing common cause failures;
  • scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
  • characterizing system reliability issues for performance;
  • charging unavailability for performance;
  • trending key parameters for condition monitoring; and
  • ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and verifying appropriate performance criteria for structures, systems and components (SSCs)/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

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

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the six

(6) maintenance and emergent work activities affecting risk-significant equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
  • Unit 2 increased risk due to the suppression pool vent path out of service on February 1, 2012;
  • Unit 2 increased risk due to power transients (reactor runback and power reductions) on February 2, 2012;
  • Unit 1 yellow risk during lower inventory condition - level in cavity below the head flange on March 3, 2012;
  • Unit 1 yellow risk during fuel shuffle no. 1 on March 11, 2012; and
  • Unit 1 yellow risk during local power range monitor (LPRM) replacements on March 14, 2012. This activity was coded as an operation with a potential for draining the reactor vessel (OPDRV).

These activities were selected based on their potential risk-significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following five (5)issues:

The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensee's evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The following engineering design package was reviewed and selected aspects were discussed with engineering personnel:

  • EC 76939, Unit 1 Alternate Decay Heat Removal (ADHR) - Secondary Loop This document and related documentation were reviewed for adequacy of the associated 10 CFR 50.59 safety evaluation screening, consideration of design parameters, implementation of the modification, post-modification testing, and relevant procedures, design, and licensing documents, and were properly updated. The inspectors observed ongoing and completed work activities to verify that installation was consistent with the design control documents.

The reactor building closed cooling water (RBCCW) system was modified to operate in conjunction with the primary loop of the supplemental spent fuel pool cooling (SSFPC)system to provide alternate decay heat removal. The modified RBCCW system will be used in place of the secondary loop of the SSFPC system. It will be a permanently available mode of operation of the RBCCW system (ADHR Mode) that will operate in parallel with normal RBCCW cooling using either the 1D (new pump) or 1A pump and the 1A or 1B RBCCW heat exchanger. The modified RBCCW system, operating in conjunction with the SSFPC primary loop, will provide fuel pool cooling capacity to allow the residual heat removal system to be shutdown for maintenance.

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following five (5)post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

  • 0PT-12.2C, No. 3 Diesel Generator Monthly load test after repair of the starting air Pressure Control Value (PCV) on January 17, 2012;
  • 0PT-10.1.1a, Reactor Core Injection Cooling System Component Test after repair of 2-E51-PCV-3006 on January 19, 2012;
  • 0PT-08.1.4a, RHR Service Water Operability Test after maintenance on 2-SW-V103 and 2-SW-V106 valves on March 13, 2012; and

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following: the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing, and test documentation was properly evaluated. The inspectors evaluated the activities against TS and UFSAR to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety.

b. Findings

No findings were identified.

1R20 Outage Activities

.1 Refueling Outage Activities

a. Inspection Scope

The inspectors reviewed the outage plan and contingency plans for the Unit 1 refueling outage commenced on March 2, 2012, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. This review included the period between February 22, 2012, and March 2, 2012, when the unit was shut down due to an inadvertent scram on February 22, 2012.

During the refueling outage, the inspectors observed portions of the cooldown process and monitored licensee controls over the outage activities listed below.

  • Licensee configuration management, including maintenance of defense-in-depth for key safety functions and compliance with applicable TS when taking equipment out of service;
  • Implementation of clearance activities and confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing;
  • Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error;
  • Controls over the status and configuration of electrical systems to ensure that TS and outage safety plan requirements were met, and controls over switchyard activities;
  • Controls to ensure that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system;
  • Reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss;
  • Controls over activities that could affect reactivity;
  • Refueling activities and fuel handling; and
  • Licensee identification and resolution of problems related to refueling outage activities.

At the end of the inspection period Unit 1 refueling outage was still ongoing.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Routine Surveillance Testing

a. Inspection Scope

The inspectors either observed surveillance tests or reviewed the test results for the following activities to verify the tests met TS surveillance requirements, UFSAR commitments, in-service testing requirements, and licensee procedural requirements.

The inspectors assessed the effectiveness of the tests in demonstrating that the SSCs were operationally capable of performing their intended safety functions.

  • 2-MST-SEIS11M, Seismic Monitoring System Channel Check and Functional Test for Unit 2 on January 13, 2012;
  • 1MST-BAT11AFY, 125VDC Battery 1A-1 Performance Capacity Test for Unit 1, on March 8, 2012.

b. Findings

No findings were identified.

.2 In-Service Testing (IST) Surveillance

a. Inspection Scope

The inspectors reviewed the performance of 0PT-7.2.4B, Core Spray Operability Test - Loop B for Unit 1 on February 3, 2012, to evaluate the effectiveness of the licensee's American Society of Mechanical Engineers (ASME)Section XI testing program for determining equipment availability and reliability. The inspectors evaluated selected portions of the following areas: 1) testing procedures, 2) acceptance criteria, 3) testing methods, 4) compliance with the licensee's IST program, TS, selected licensee commitments, and code requirements, 5) range and accuracy of test instruments; and 6) required corrective action.

b. Findings

No findings were identified.

.3 Containment Isolation Valve Testing

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

The inspectors observed in-plant activities and reviewed procedures and associated records to determine whether: any preconditioning occurred; acceptance criteria were clearly stated and were consistent with the system design basis; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; test data and results were accurate, complete, within limits, and valid; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; equipment was returned to a position or status required to support the performance of its safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the corrective action program.

b. Findings

No findings were identified.

1EP6 Emergency Planning Drill Evaluation

a. Inspection Scope

The inspectors observed the site emergency preparedness training drill conducted on January 15, 2012. The inspectors reviewed the drill scenario narrative to identify the timing and location of classifications, notifications, and protective action recommendations development activities. During the drill, the inspectors assessed the adequacy of event classification and notification activities. The inspectors observed portions of the licensee's post-drill critique. The inspectors verified that the licensee properly evaluated the drill's performance with respect to performance indicators and assessed drill performance with respect to drill objectives.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

Radiological Hazard Assessment and Exposure Controls. The inspectors evaluated licensee performance in assessing radiological hazards and controlling worker access to radiologically-significant areas. The inspectors evaluated communications to the workers, contamination and radioactive material control, radiological hazard controls to include work coverage, controls and contingencies for risk significant high radiation areas (HRA) and very high radiation areas (VHRA), radiation worker practices and technician proficiency and problem identification and resolution.

Radiological Hazard Assessment. During facility tours, the inspectors directly observed postings and physical controls for radiation areas, HRAs, locked HRAs (LHRA), VHRAs, and potential airborne radioactivity areas established within the radiologically-controlled area (RCA) of the Unit 1 (U1) drywell, Unit 1 (U1) and U2 reactor and turbine buildings, Independent Spent Fuel Storage Installation (ISFSI), and radioactive waste (radwaste)processing and storage locations. The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. Results were compared to current licensee surveys and assessed against established postings and Radiation Work Permit (RWP) controls. Licensee key control and access barrier effectiveness were evaluated for selected LHRA and VHRA locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with radiation protection (RP) supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool (SFP) were reviewed and discussed. In addition, licensee controls for areas where dose rates could change significantly because of plant shutdown and refueling operations associated with the U1 refueling outage (U1 RFO 19) were reviewed and discussed. The licensee's deployment of portable air monitors was reviewed and the airborne radioactivity monitoring program was discussed with cognizant RP personnel.

Instructions to Workers: As part of the review the inspectors reviewed the As Low As Reasonably Achievable (ALARA) packages and RWPs for selected U1 RFO 19 activities. The inspectors observed RP personnel providing entry briefings to workers entering the U1 drywell, reactor building, and turbine building to conduct work associated with torus diving, radiography activities, MSIV activities, "A" & "B" main condensers, chemical decontamination associated with reactor water cleanup activities, inboard MSIV activities, and torus diving activities. Container labeling was reviewed for legibility, currency and clarity for selected areas of the U1 drywell, U1 and U2 reactor and turbine buildings, radwaste processing areas, ISFSI, and in the RCA of the yard.

Contamination and Radioactive Material Control. The inspectors observed the routine release of materials and personnel from the RCA. The sensitivity of the instrumentation was discussed with selected RP personnel. The inspectors reviewed the radioactive source inventory and verified the physical presence of the most radiologically-significant sources. The inspectors reviewed a memo documenting the transmittal of database information submitted to the National Source Tracking System per 10 CFR 20.2207.

Radiological Hazards Control and Work Coverage. The inspectors reviewed radiological conditions for consistency with posted surveys, RWPs and worker briefings. The RP controls were assessed for area radiation surveys, radiation postings, radiation contamination controls and RP job coverage for selected U1 RFO 19 work activities. The inspectors observed selected U1 RFO 19 job coverage for activities associated with the refueling floor and controls for highly activated or contaminated materials stored underwater. The inspectors observed selected U1 RFO 19 work activities via closed circuit television in the remote monitoring room. During tours of the licensee facilities, the inspectors checked postings and verified locking on areas with dose rates greater than 1,000 millirem per hour at 30 centimenters from the source.

Risk-Significant HRA and VHRA Controls: The inspectors discussed the controls for high risk HRAs and VHRAs with the RP Manager. The procedures that would be implemented where conditions had changed or were reasonably expected to change resulting in the creation of HRA, LHRA or VHRA were discussed with selected operational RP Supervisors. The inspectors observed RP staff issuing LHRA keys for selected U1 RFO 19 work activities. In addition, the inspectors reviewed and discussed the controls in place for the LHRA key maintained by Security and Operations.

Radiation Worker and Technician. The inspectors observed radiation worker performance and RP technician (RPT) proficiency during tours of selected areas of the plant. The inspectors reviewed corrective action program documents identifying radiation worker performance issues and RPT proficiency. The inspectors reviewed the corrective action program documents for determination of reporting threshold, as well as adequacy of resolution of the reported problems. The review included an evaluation of selected electronic dosimeter (ED) alarms to determine if the identified events constituted exceeding the performance indicator reporting thresholds.

RP activities were evaluated against the requirements of UFSAR Section 12; TS 5.7.1 and 5.7.2., 10 CFR Parts 19 and 20; and approved licensee procedures.

Problem Identification and Resolution. Licensee corrective action program documents associated with access control to radiologically-significant areas were reviewed and assessed. This included review of selected Nuclear Condition Reports (NCRs) related to radworker and RPT performance. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with procedure CAP-NGGC-200, Condition Identification and Screening Process, Revision (Rev.) 34. The inspectors also evaluated the scope of the licensee's internal audit program and reviewed recent assessment results.

The inspectors completed all specified line-items detailed in Inspection Procedure (IP)71124.01 (sample size of 1).

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

Event Report and Effluent Report Reviews. The inspectors reviewed the 2009 and 2010 Annual Radiological Effluent Release Report documents for consistency with the requirements in the Offsite Dose Calculation Manual (ODCM) and TS details. Routine and abnormal effluent release results and reports, as applicable, were reviewed and discussed with responsible licensee representatives. Status of the radioactive gaseous and liquid effluent processing and monitoring equipment and activities, and changes thereto, as applicable, as described in the current UFSAR, ODCM, Engineering Change 50.59 Reviews, and recent radiological monitoring system Health Reports were discussed with responsible staff. Proposed and actual changes reviewed in detail included Storm Drain Stabilization Pond liquid mitigation and release activities and engineering changes associated with the U2 Salt Water Release Tank.

Equipment Walk Downs. The inspectors walked down and discussed selected components of U1 gaseous processing systems, and selected liquid waste processing and discharge systems to ascertain material condition, configuration and alignment. The walk-downs conducted with chemistry and operations personnel included direct observations and discussion of equipment and radiation monitors associated with the U1 Turbine Building (TB) ventilation, Standby Gas Treatment (SGT) system, and plant stack systems focusing on equipment material condition, operational status, and configuration controls. For liquid radioactive systems, the inspectors evaluated radioactive waste building systems with focus on recent activities and changes to equipment such as completion of the U2 Salt Water Release Tank system and equipment for waste processing capabilities.

Sampling and Analyses. Procedural details for liquid and on-going gaseous effluent radionuclide release activities including representative sampling and set-point determinations were discussed with responsible chemistry staff. The inspectors verified completion of compensatory activities for liquid releases made during periods of inoperable monitoring instrumentation. Results for inter-laboratory sample Quality Assurance analyses were reviewed and discussed.

Instrumentation and Equipment. The inspectors discussed and verified sample line and system flow rates for the Unit 1 plant stack, SGT system, and TB ventilation systems. For selected systems, sampling and processing of weekly effluent release permits were discussed with responsible chemistry staff. In addition, the inspectors directly observed vendor testing of the 1B SGT system High Efficiency Particulate Air and charcoal filters.

Effluents and Dose Calculations. The inspectors reviewed and evaluated continuous gaseous release data from the Plant Stack, and batch liquid release data for select Waste Storage Tank systems and the Storm Drain Stabilization Pond (SDSP). Total radionuclide release and dose impacts were reviewed and discussed for Calendar Year (CY) 2009 through CY 2011. The impact of estimated carbon-14 releases on reported doses were reviewed and discussed with responsible licensee representatives. The inspectors discussed tracking and evaluation of abnormal releases, as applicable, for CY 2009 through CY 2011.

Problem Identification and Resolution. The inspectors reviewed selected corrective action program AR documents in the areas of gaseous and liquid effluent processing and release activities. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with CAP -NGGC-0200, Condition Identification and Screening Process, Rev. 34. The inspectors also discussed the scope of the licensee's internal audit program and reviewed recent assessment results.

Effluent process and monitoring activities were evaluated against details and requirements documented in the UFSAR Sections 11 and 12; TS Sections 3.6.4.3, SGT System, 5.4, Procedures, 5.5., Programs and Manuals, and 5.6, Reporting Requirements; ODCM; 10 Code of Federal Regulations (CFR) Part 20; 10 CFR, Appendix I to Part 50; and approved licensee procedures. Records reviewed are listed in Sections

2RS6 and 2RS7.

In addition, ODCM and UFSAR changes since the last onsite inspection were reviewed against the guidance in NUREG-1301 and Regulatory Guide (RG) 1.109, RG 1.21, and RG 4.1.

The inspectors completed all of the specified line-item samples detailed in IP 71124.06 (sample size of 1). Aspects of the licensee's ground water monitoring initiative are detailed in Section

2RS7 of the Attachment.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program (REMP)

a. Inspection Scope

REMP Implementation. The inspectors observed routine sample collection and surveillance activities as required by the licensee's environmental monitoring program. The inspectors noted the material condition and operability of airborne particulate filter and iodine cartridge sample stations and observed collection of weekly air samples at selected monitoring locations. Environmental thermoluminescent dosimeters at selected sites were checked for material condition. In addition, the inspectors observed collection of surface water samples in Nancy's Creek and the Cape Fear River. The inspectors determined the current location of selected sample points using global positioning system instrumentation. Land use census results, changes to the ODCM, monitoring for hard-to-detect radionuclides, and sample collection/processing activities were discussed with environmental technicians and licensee staff.

The inspectors reviewed the last two calibration records for selected environmental air samplers. The inspectors also reviewed the 2010 Radiological Environmental Operating Report, the 2010 Annual Radioactive Effluent Report, results of the 2011 interlaboratory cross-check program for the Harris Energy & Environmental Center, and procedural guidance for environmental sample collection and processing. Selected environmental measurements were reviewed for consistency with licensee effluent data, evaluated for radionuclide concentration trends, and compared with detection level sensitivity requirements.

Meteorological Monitoring Program. The inspectors observed the physical condition of the tower and its instrumentation and discussed equipment operability and maintenance history with licensee staff. The inspectors evaluated transmission of locally generated meteorological data to other licensee groups such as main control room operators. For the meteorological measurements of wind speed, wind direction, and temperature, the inspectors reviewed the last two calibration records for applicable tower instrumentation.

The inspectors also evaluated measurement data recovery for 2011.

Groundwater Monitoring Program. The inspectors held a meeting with licensee staff and a State of North Carolina radiation safety representative to discuss the status of BSEP's groundwater monitoring program. The licensee provided an update on tritium concentrations in water collected from onsite and offsite groundwater and surface water sampling locations and discussed ongoing remediation efforts associated with the Storm Drain Stabilization Pond (SDSP) and areas near a Condensate Storage Tank (CST) underground pipe leak. Although seasonal fluctuations can occur, the inspectors noted that onsite tritium concentrations in and near the SDSP have generally trended downward since 2007 when the contamination was discovered and corrective actions were initiated. The licensee has recently installed intermediate-depth monitoring wells in the vicinity of the CST piping leak in order to directly monitor the Castle-Hayne aquifer. The inspectors also noted that although very low concentrations of tritium have been identified periodically in the offsite environs, e.g., Nancy's Creek immediately adjacent to the SDSP, all reported values for offsite samples have remained significantly below established regulatory limits. The licensee has completed a network of sub-surface pumping wells designed to remediate the groundwater around the SDSP and near the CST piping leak. The licensee has also completed construction of a new, double-lined, pond to replace the SDSP.

The inspectors discussed program guidance for dealing with spills, leaks, and unexpected discharges with licensee staff and reviewed recent entries into the 10 CFR 50.75(g) decommissioning file. The inspectors reviewed and discussed the licensee's program for monitoring of structures, systems, and components with the potential to release radioactive material to the environment and walked down components of the liquid effluent discharge system. Potential effluent release points due to onsite surface water bodies (e.g., the SDSP) were also evaluated.

Identification and Resolution of Problems. The inspectors reviewed selected NCRs in the areas of radiological environmental monitoring and meteorological tower maintenance. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure CAP-NGGC-0200, Condition Identification and Screening Process, Rev. 34. The inspectors also evaluated the scope of the licensee's internal audit program and reviewed recent assessment results.

REMP implementation, meteorological monitoring, and groundwater protection activities were reviewed against the guidance and requirements of 10 CFR Part 20; Appendices E and I to 10 CFR Part 50; TS Section 5.0; UFSAR Chapter 2; ODCM; RG 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment"; Safety Guide 23, "Onsite Meterological Programs"; Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program" - 1979; Nuclear Energy Institute 07-07, "Industry Groundwater Protection Initiative - Final Guidance Document"; and approved licensee procedures.

The inspectors completed all specified line-items detailed in IP 71124.07 (sample size of 1).

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

a. Inspection Scope

Waste Processing and Characterization. During inspector walk-downs, accessible sections of the liquid and solid radwaste processing systems were assessed for material condition and conformance with system design diagrams.

Inspected equipment included radwaste storage tanks, resin transfer piping, resin and filter packaging components, and unused evaporator equipment.

The inspectors discussed component function, processing system changes, and radwaste program implementation with licensee staff.

In addition, the inspectors completed a walkdown of a spent resin transfer system and dewatering facility and the low level radioactive waste facility where shredding and compacting of Dry Active Waste (DAW) is performed.

The 2010 Radioactive Effluent Release Report, and radionuclide characterizations from 2010 for the DAW waste stream and individual resin liner characterizations were reviewed and discussed with radwaste staff. The inspectors evaluated analyses for hard-to-detect nuclides and reviewed the use of scaling factors. Waste stream mixing and concentration averaging methodology for resins and filters was evaluated and discussed with radwaste staff. The inspectors also reviewed the licensee's procedural guidance for monitoring changes in waste stream isotopic mixtures.

Radwaste processing activities and equipment configuration were reviewed for compliance with the licensee's Process Control Program (PCP) and FSAR, Chapter 11. Waste stream characterization analyses were reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 61, and guidance provided in the Branch Technical Position on Waste Classification (1983).

Radioactive Material Storage. During walk-downs of indoor and outdoor radioactive material storage areas, the inspectors observed the physical condition and labeling of storage containers and the posting of Radioactive Material Areas. The inspectors also reviewed licensee procedural guidance for storage and monitoring of radioactive material.

Radioactive material and waste storage activities were reviewed against the requirements of 10 CFR Part 20.

Transportation: The inspectors directly evaluated licensee actions during preparation of a resin liner for shipment. The inspectors noted package markings and labeling, observed actual dose rate measurements being performed, and interviewed shipping technicians regarding their knowledge of Department of Transportation (DOT) regulations.

Selected shipping records were reviewed for consistency with licensee procedures and compliance with NRC and DOT regulations. The inspectors reviewed emergency response information, DOT shipping package classification, waste classification, and radiation survey results; and evaluated whether receiving licensees were authorized to accept the packages. Licensee procedures for opening and closing Type A shipping containers were compared to manufacturer requirements. In addition, training records for selected individuals currently qualified to ship radioactive material were reviewed.

Transportation program implementation was reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178, as well as the guidance provided in NUREG-1608. Training activities were assessed against 49 CFR Part 172 Subpart H.

Problem Identification and Resolution. The inspectors reviewed CRs in the area of radwaste/shipping. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure CAP-NGGC-0200, Condition Identification and Screening Process, Rev. 34. The inspectors also evaluated the scope of the licensee's internal audit program and reviewed recent assessment results.

The inspectors completed all specified line-items detailed in IP 71124.08 (sample size of 1).

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

.1 Initiating Events Cornerstone

a. Inspection Scope

To verify the accuracy of the PI data reported to the NRC, the inspectors compared the licensee's basis in reporting each data element listed below to the PI definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline.

  • Unplanned scrams per 7000 Critical Hours
  • Unplanned scrams with complications
  • Unplanned power changes per 7000 Critical Hours The inspectors sampled licensee submittals for the performance indicators listed above for the period from the 1 st quarter, 2011 through the 4 th quarter, 2011. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports and NRC inspection reports for the period to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Radiation Safety

a. Inspection Scope

The inspectors sampled licensee records to verify the accuracy of reported Performance Indicator (PI) data for the periods listed below. To verify the accuracy of the reported PI elements, the reviewed data were assessed against guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline".

Occupational Radiation Safety Cornerstone. The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for the Occupational Radiation Safety Cornerstone from January 1 to December 31, 2011. For the assessment period, the inspectors reviewed ED alarm logs and selected ARs related to controls for exposure significant areas. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in sections

2RS1 and 4OA1 of the Attachment.

Public Radiation Safety Cornerstone. The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from January 1 through December 31, 2011. For the assessment period, the inspectors reviewed cumulative and projected doses to the public and AR documents related to Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual issues. Documents reviewed are listed in sections 2RS6, 2RS7, and

4OA1 of the Attachment.

The inspectors completed all of the specified line-item samples associated with the Occupational and Public Radiation Protection Cornerstones detailed in IP 71151.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

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

a. Inspection Scope

To aid in the identification of repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed frequent screenings of items entered into the licensee's corrective action program. The review was accomplished by reviewing daily action request reports.

b. Findings

No findings were identified.

.2 Selected Issue Follow-up Inspection

a. Inspection Scope

The inspectors selected AR 234689234689 High Pressure Coolant Injection Discharge Valve Testing for detailed review. This AR was associated with In-Service Testing requirements of the high pressure core injection pump discharge valve (E41-F005). The inspectors reviewed this report to verify that the licensee identified the full extent of the issue, performed an appropriate evaluation, and specified and prioritized appropriate corrective actions. The inspectors evaluated the report against the requirements of the licensee's corrective action program as delineated in corporate procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B.

b. Findings

No findings were identified.

4OA3 Follow-up of Events

.1 (Closed) LER 05000325, 324/2011-03-00, Loss of Control Room Air Conditioning and Emergency Ventilation

a. Inspection Scope

The inspectors reviewed the plant's response to a loss of control room air conditioning and emergency ventilation systems due to a loss of control room instrument air pressure on December 1, 2011. The loss of control room instrument air pressure was caused by ice blockage in the air tubing internal to the air dryer. The air dryer froze the moisture in the air tubing due to inadequate refrigerant pressure in the air dryer cooling circuit. A self-revealing non-cited violation was identified and is described below.

b. Findings

Introduction:

A self-revealing Green non-cited violation of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, was identified for the licensee's failure to promptly identify and correct a condition adverse to quality related to the Control Room AC system and the CREV system. Specifically, the licensee failed to identify and correct a slow refrigerant leak in the instrument air dryer in the control building HVAC instrument air system rendering both the control room AC and CREV systems inoperable.

Description:

The control room AC system is designed to permit continuous occupancy in the control room, computer rooms, and electronic workrooms under normal operating conditions and under the design basis accident. The AC system for the control building includes three

(3) air conditioning systems. One system is for the Unit 1 area of the control room and one system is for the Unit 2 area of the control room. The third system is a 100 percent redundant system, which can be utilized for either Unit.

The CREV System provides the additional filtering and positive pressure necessary to maintain habitable conditions within the control room area during emergency situations. The CREV system consists of two filtering trains, each consisting of an emergency air filter and recirculation fan. One filtering train is required for system operation with the other serving as the 100 percent redundant standby system. The three AC units and the CREV system require instrument air to operate.

The instrument air system dryer uses a refrigerant system to cool moisture in the air tubing and drains the moisture out of the air tubing through a moisture separator installed at a low point in the tubing below the air dryer. On December 1, 2011, at approximately 1:44 p.m., ambient temperature was above freezing, but the air dryer cooled the moisture in the instrument air tubing to below freezing. The moisture froze and blocked the instrument air line. The line blockage prevented the air compressors from maintaining system air pressure, and prevented the three control room AC units and both CREV trains from operating. The instrument air dryer was bypassed, air pressure was restored, and the control room AC and CREV systems were restored at 2:20 p.m. on December 1, 2011. The moisture in the instrument air dryer froze because the seals in the refrigerant circuit leaked, causing the refrigerant pressure in the system to slowly decrease. Lowering refrigerant pressure resulted in the refrigerant reaching saturation temperature and freezing the moisture in the air line.

Licensee Procedure EGR-NGGC-0010 , System Component Trending Program and System Notebooks, provides instructions for monitoring structures, systems, and components (SSCs) to permit early detection of SSC problems. The Trending Program is used to address SSCs whose performance could affect the plant's safety. Under this procedure, engineering responsibilities include trending and evaluating data to identify and correct problems. However, trending for the instrument air dryer refrigerant pressure was not adequate to identify and correct the slowly lowering refrigerant pressure. Trending was inadequate because the data was not recorded in a way that it was able to be trended and the data was not recorded frequently enough.

Analysis:

The failure to identify and correct the slowly lowering refrigerant pressure was a performance deficiency. This finding was more than minor because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone. It also adversely affected the cornerstone objective of maintaining a radiological barrier for the control room. Specifically, the finding led to a loss of all air conditioning and filtering capability of control room air. The significance determination was completed in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 4a for the Barrier Integrity Cornerstone. The finding was determined to be of very low safety significance (Green) because it only affected the radiological barrier function of the control room, and did not represent a degradation of the smoke or toxic atmosphere barrier function of the control room. This finding has a cross-cutting aspect in the Corrective Action Program component of the Problem Identification and Resolution area because the licensee did not identify the issue completely, accurately, and in a timely manner commensurate with its safety significance. [P.1 (a)]

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, in December 2011 the licensee failed to promptly identify and correct a condition adverse to quality regarding a slow refrigerant leak in the instrument air dryer in the control room AC and CREV systems. This resulted in failure of the control room AC and CREV systems. Upon discovery of the issue the licensee bypassed the instrument air dryer, and restored the control room AC and CREV systems. Because this finding is of very low safety significance (Green), and has been entered into the licensee's corrective action program as AR 502214502214 this violation is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000325, 324/2012002-01, Failure to Identify and Correct a Refrigerant Leak in the Instrument Air Dryer System.

This LER is closed.

.2 Unit 1 Reactor Scram Due to Loss of Common C Switchgear

a. Inspection Scope

On February 22, 2012, inspectors responded to the plant and performed observations after the Unit 1 reactor was manually scrammed in response to the loss of the Common C switchgear. Inspectors evaluated operator performance compared to procedural guidance. After the plant was stabilized, inspectors reviewed operator logs, plant computer data, recorder data, plant procedures, and training to determine if personnel response was appropriate, if plant equipment responded as expected, if the cause of the plant trip was accurately determined, and if appropriate immediate corrective actions were taken.

b. Findings

.

No findings were identified.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 20, 2012, the inspectors presented the inspection results to Mr. M. Annacone and other members of the licensee staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection period.

.2 Interim Exit Meetings

The following interim exits were conducted:

On March 8, 2012, the inspectors discussed results of the onsite RP inspection with Mr. M. Annacone, Site Vice President, and other cognizant licensee representatives. The inspectors noted that no proprietary information was reviewed during the course of the inspection. No findings of significance were identified.

On March 16, 2012, the inspectors presented the in-service inspection (ISI) results to the Site Vice-President, Mr. M. Annacone and other members of the licensee management staff. A re-exit meeting was conducted on March 23, 2012, by telephone. All proprietary information that was provided to the inspector was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Annacone, Site Vice President
S. Bostic, Supervisor - Major Projects
A. Brittain, Manager - Security
J. Burke, Director - Engineering
C. Dunsmore, Manager - Shift Operations
P. Dubrouillet, Manager - Training
J. Frisco, Plant General Manager
C. George, Manager - BOP Systems Engineering
K. Gerald, Acting Manager - Maintenance
S. Gordy, Manager - Operations
L. Grzeck, Acting Supervisor - Licensing and Regulatory Affairs
R. Ivey, Manager - Nuclear Oversight Services
F. Jefferson, Manager - ECCS Systems Engineering
J. Johnson, Manager - Environmental and Radiological Controls
S. Larson, ISI Program
M. McGowan, Supervisor - Environmental
M. Millinor, Sr. Chemistry Specialist
R. Mosier, Communication Specialist
W. Murray, Licensing Specialist
D. Petrusic, Superintendent - Environmental and Chemistry
A. Pope, Manager - Support Services
J. Price, Manager - Design Engineering
E. Rochelle, Supervisor - Radiation Protection
T. Sherrill, Engineer - Technical Support
P. Smith, Superintendent - Electrical, Instrumentation, and Controls Maintenance
G. Spry, Site Welding/Repair & Replacement
J. Sullivan, IWE/IWL Programs
M. Turkal, Lead Engineer - Technical Support
J. Vincelli, Superintendent - Radiation Protection
S. Williams, Vessel Internals Program
E. Wills, Director - Site Operations

State of North Carolina Personnel

Patrick Cox, Health Physicist, Department of Environment and Natural Resources (NCDENR)

NRC Personnel

Randall

A. Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000325, 324/2012002-01 NCV Failure to Identify and Correct a Refrigerant Leak in the Instrument Air Dryer System (4OA3)

Closed

05000325, 324/2011-03-00 LER Loss of Control Room Air Conditioning and Emergency Ventilation (4OA3)

LIST OF DOCUMENTS REVIEWED

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