IR 05000445/2013005

IR 05000445-13-005, 05000446-13-005; 9/26/2013 - 12/31/2013; Comanche Peak Nuclear Power Plant, Units 1 and 2 Integrated Resident and Regional Report; Operability Evaluations and Functionality Assessments, Plant Modifications

ML14036A060
Person / Time
Site:	Comanche Peak
Issue date:	02/04/2014
From:	Walker W C NRC/RGN-IV/DRP
To:	Flores R Luminant Generation Co
References
IR-13-005
Download: ML14036A060 (40)

Text

February 4, 2014

Rafael Flores, Senior Vice President and Chief Nuclear Officer Luminant Generation Company, LLC Comanche Peak Nuclear Power Plant P.O. Box 1002 Glen Rose, TX 76043 Subject: COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2013005 AND 05000446/2013005

Dear Mr. Flores:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 9, 2014, the NRC inspectors discussed the results of this inspection with Mr. K. Peters, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. NRC inspectors documented two findings of very low safety significance (Green) in this report. One of these findings involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2. In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Wayne C. Walker, Branch Chief Project Branch A Division of Reactor Projects Docket Nos.: 05000445, 05000446 License Nos.: NPF-87, NPF-89

Enclosure:

Inspection Report 05000445/2013005 and 05000446/2013005

w/Attachments:

1. Supplemental Information 2. Request for Information - Occupational Radiation Safety Inspection cc w/encl: Electronic Distribution

SUMMARY

IR 05000445/2013005, 05000446/2013005; 9/26/2013 - 12/31/2013; Comanche Peak Nuclear Power Plant, Units 1 and 2 Integrated Resident and Regional Report; Operability Evaluations and Functionality Assessments, Plant Modifications The inspection activities described in this report were performed between September 26, 2013, and December 31, 2013, by the resident inspectors at the Comanche Peak Nuclear Power Plant and six inspectors from the NRC's Region IV office. Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process." Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC~s Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection in the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle. The licensee entered the finding into the corrective action program as Condition Report CR-2013-005097. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not follow documented instructions and ensure no foreign material remained in the sump after the inspection. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process for Findings At-Power," the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure the work instruction was adequate for the inspection activity H.2(c)(Section 1R15).

Green.

The inspectors reviewed a self-revealing finding for the failure of maintenance personnel to follow work instructions. Specifically, maintenance personnel failed to follow instructions and cut the wrong cable during a transformer modification. As a result, one offsite power source to both units was unavailable during the repair of the damaged cable. The licensee entered the finding into the corrective action program as Condition Report CR-2013-011124.

The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process for Findings At Power," the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with work practices in that the licensee personnel failed to use human performance error prevention techniques such as self and peer checking when cutting cables H.4(a)(Section 1R18).

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Unit 1 began the inspection period at approximately 100 percent power. On November 15, 2013, operators reduced power to approximately 75 percent for turbine valve testing. The unit returned to approximately 100 percent power the next day. On December 4, 2013, operators reduced power to approximately 95 percent in response to a loss of offsite power to the safety-related 6.9 kV buses. The unit returned to approximately 100 percent power the same day and operated at that power level for the remainder of the inspection period. Unit 2 began the inspection period at approximately 100 percent power. On November 1, 2013, the unit experienced an automatic reactor trip during a solid state protection system relay test.

On November 3, 2013, operators performed a reactor startup and placed the unit on the grid.

The unit achieved approximately 100 percent power the following day. On December 4, 2013, operators reduced power to approximately 92 percent in response to a loss of offsite power to the safety-related 6.9 kV buses. The unit returned to approximately 100 percent power the same day and operated at that power level for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 7, 2013, the inspectors completed an inspection of the station's readiness for seasonal extreme weather conditions. The inspectors reviewed the licensee's adverse weather procedures for cold weather and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to cold weather the licensee had corrected weather-related equipment deficiencies identified during the previous season. The inspectors selected the following risk-significant systems that were required to be protected from the cold weather:

• Fire protection system

• Station service water system

• Radiation monitoring system The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensee's procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the systems.

These activities constituted one sample of readiness for seasonal adverse weather as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On October 29, 2013, the inspectors performed a walkdown of the protected area to access the station's readiness for impending adverse weather conditions. The inspectors specifically looked for any loose debris that could become missiles during a high wind condition. In addition, the inspectors reviewed the licensee's implementation procedure for high winds. These activities constitute completion of one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

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

• October 16, 2013, Units 1 and 2 service water, transformer XST2, and Unit 2 alternate power diesel generators when transformer XST1 was unavailable during modification activities

• November 20, 2013, Unit 2, diesel generator 2-01 when diesel generator 2-02 was unavailable for maintenance and modifications

• December 5, 2013, Unit 2, diesel generator 2-02 when both sources of offsite power were unavailable and diesel generator 2-02 was supplying emergency power The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. The inspectors verified that critical portions of the systems were correctly aligned for the existing plant configuration.

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

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of the Unit 2 component cooling water system to verify the functional capability of the system. The inspectors walked down the system to review mechanical and electrical equipment line-ups, system pressure and temperature indications, component labeling, component lubrication, hangers and supports, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system's function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment problems were being identified and appropriately resolved.

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

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on the following plant areas important to safety:

• October 15, 2013, fire zone SB8, Unit 1 safeguards building 810' corridor

• November 18, 2013, fire area FP, fire protection pump house

• December 14, 2013, fire zone 1SG10A, diesel generator 1-01 room

• December 14, 2013, fire zone 1SI12A, diesel generator 1-02 room For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constitute completion of four quarterly inspection samples as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On October 21, 2013, the inspectors observed a simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the scenario.

These activities constitute completion of one quarterly review of licensed operator requalification sample as defined in Inspection Procedure 71111.11.

a. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

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

• October 23, 2013, Unit 2, transfer of controlling channel of steam generator level instrumentation

• October 30, 2013, Units 1 and 2, operator performance during unplanned inoperability of transformer XST1

• November 2, 2013, Unit 2, operator performance following the Unit 2 reactor trip

• December 5, 2013, Units 1 and 2, transfer of safety-related 6.9 kV bus power supply from the diesel generators to offsite power These activities constitute completion of one quarterly review of licensed operator performance sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Inspection The licensed operator requalification program involves two training cycles that are conducted over a 2-year period.

In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, Comanche Peak Nuclear Power Plant was in the first part of the training cycle.

a. Inspection Scope

The inspectors reviewed the results of the operating tests for the plant to satisfy the annual inspection requirements. On January 2, 2014, the licensee informed the lead inspector of the results:

• 15 of 16 crews passed the simulator portion of the operating test

• 88 of 94 licensed operators passed the simulator portion of the operating test

• 92 of 94 licensed operators passed the job performance measure portion of the operating test All the failures were successfully remediated prior to being returned to licensed duties. These activities constitute completion of one annual licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the degraded performance or condition of the following risk-significant structures, systems, or components:

• Unit 2 safety injection accumulators

• Units 1 and 2 plant computer system

• Unit 1 reactor trip switchgear

• Unit 2 diesel generators The inspectors reviewed the extent of condition of possible common cause structure, system, or component failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the structures, systems, or components. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule. These activities constituted completion of four maintenance effectiveness samples as defined in Inspection Procedure 71111.12.

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 maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• October 7, 2013, risk associated with 345 kV breaker maintenance

• October 16, 2013, risk associated with transformer XST1 outage

• December 5, 2013, risk associated with no offsite power available to the safety-related 6.9 kV buses The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

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

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components:

• Condition Report CR-2013-005097, Unit 1, tape in containment sump

• Condition Report CR-2013-008947, Units 1 and 2, containment airlock gauge classification

• Condition Report CR-2013-010297 associated with unprotected ammeter wiring

• Condition Report CR-2013-011425 associated with diesel generator 2-01 shutdown system activated light not illuminated

• Condition Report CR-2013-011618, Units 1 and 2, post-accident sampling system containment isolation valves

• Condition Report CR-2013-012209, Unit 2, atmospheric relief valve current to pressure (I/P) convertor failure The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded structures, systems, or components to be operable, the inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability.

The inspectors reviewed Operating Experience Smart Sample (OpESS) FY2007-01, "PWR Containment Sump Recirculation Pipe Foreign Material Blockage," in the evaluation of Condition Report CR-2013-005097. These activities constitute completion of six operability evaluation inspection samples as defined in Inspection Procedure 71111.15.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection in the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle.

Description.

On April 16, 2013, the inspectors observed the performance of the Unit 1 containment sump inspection. The inspectors observed four circular sections of red tape inside the containment sump. The licensee had used red duct tape as a wheel cover for the inspection robot to prevent contamination. The four tape sections, observed by the inspectors, had fallen off the robot wheels during the previous inspection and remained inside the sump for the complete operating cycle, 18 months. The licensee personnel performing the inspection also observed the tape in the sump and informed supervision of the observation. The licensee developed and implemented a plan to remove the tape. The inspectors ultimately questioned the licensee about the past operability of the tape in the sump. Based on the inspectors' questioning, the licensee realized the tape had been in the sump for a complete operating cycle. The licensee contracted with a vendor to evaluate the effects of the tape on the plant equipment during the recirculation phase of an accident. The licensee concluded that the components and systems would remain capable of performing their intended safety function. The inspectors agreed with the licensee's assessment and concluded that the evaluation was thorough. The inspectors reviewed work order 3936127 that was used by the licensee personnel to perform the containment sump inspection. The inspectors observed that the work order directed that housekeeping zone II, cleanliness class B, be in effect in the immediate area of the containment spray and residual heat removal flue openings. The inspectors concluded that, although the necessary steps for housekeeping were included in the instructions, the instructions were not clearly organized.

Analysis.

The licensee's failure to follow documented instructions when performing the containment sump inspection was a performance deficiency. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not follow documented instructions and ensure no foreign material remained in the sump after the inspection. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure the work instruction was adequate for the inspection activity H.2(c).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. Work Order 3936127, used to perform a containment emergency sump inspection, an activity affecting quality, directed housekeeping zone II, cleanliness class B, be in effect in the immediate area of the containment spray and residual heat removal flue openings. Contrary to the above, on October 14, 2011, the licensee performed an activity affecting quality and failed to accomplish the activity in accordance with documented instructions. Specifically, the licensee failed to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection on the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle. After identification of the tape, the licensee removed the tape from the sump.

Since the violation was of very low safety significance and was documented in the licensee's corrective action program as Condition Report CR-2013-005097, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000445/2013005-01, "Failure to Follow Instructions for Containment Sump Inspection Results in Debris Left in the Sump."

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed work instructions and condition reports associated with the plant modification of transformer XST1. The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. These activities constitute completion of one plant modifications inspection sample as defined in Inspection Procedure 71111.18.

b. Findings

Introduction.

The inspectors reviewed a Green self-revealing finding for the failure of maintenance personnel to follow work instructions. Specifically, maintenance personnel failed to follow instructions and cut the wrong cable during a transformer modification. As a result, one offsite power source to both units was unavailable during the repair of the damaged cable.

Description.

On October 30, 2013, during the performance of work order 4651370, maintenance personnel inadvertently cut the neutral phase of the ground protection circuit for transformer XST1. During the activity, the first craftsman correctly identified the cable to be cut. The first craftsman shook the cable so the second craftsman, with the cutting tool, would be able to identify the cable needing to be cut. The first craftsman maintained his hand on the cable to further identify the cable to cut. The second craftsman observed movement in a different cable, grabbed the cable, and proceeded to cut the incorrect cable. The craftsmen were standing next to each other when the incorrect cable was cut and both failed to prevent the cutting of the incorrect cable.

The inspectors discussed the finding with the licensee and reviewed the licensee's cause analysis. The inspectors determined that electricians performing the activity failed to use proper human performance error prevention techniques and cut the wrong cable.

Analysis.

The failure of maintenance personnel to follow instructions when cutting a cable was a performance deficiency. As a result, the incorrect cable was cut and one source of offsite power was unavailable to both units. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Appendix A, Exhibit 2 "Mitigating Systems Screening Questions," the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with work practices in that the licensee personnel failed to use human performance error prevention techniques such as self and peer checking when cutting cables H.4(a).

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The licensee documented the finding in the corrective action program as Condition Report CR-2013-011124. Because the finding does not involve a violation and is of very low safety significance, it is being characterized as finding FIN 05000445/2013005-02; 05000446/2013005-02, "Cutting Incorrect Cable Results in an Inoperable Offsite Power Source."

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities that affected risk-significant structures, systems, or components:

• October 2, 2013, Unit 1, positive displacement charging pump testing following flange gasket replacement

• October 21, 2013, Unit 1, auxiliary feedwater flow instrument check following instrument manifold replacement

• November 6, 2013, Unit 1, charging pump 1-01 testing following motor breaker control device replacement

• November 15, 2013, Unit 1, steam generator narrow range level 0519 testing following lead/lag amplifier card replacement

• December 3, 2013, Unit 1, diesel generator 2-02 auxiliary jacket water pump test following mechanical seal replacement

• December 16, 2013, Unit 1, offsite sources operability following breaker control device replacement

• December 17, 2013, Units 1 and 2, spent fuel pool cooing water pump X-02 post-maintenance check following pump and motor oil change The inspectors reviewed licensing and design basis documents for the structures, systems, or components and the maintenance and post-maintenance test procedures.

The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, or components. These activities constitute completion of seven post-maintenance testing samples as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed risk-significant surveillance tests and reviewed test results to verify that the tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions: Routine Surveillance Testing

• October 7, 2013, Unit 2, train A reactor trip breaker testing in accordance with Procedure OPT-447B, "Mode 1, 3 and 4 Train A SSPS Actuation Logic Test," Revision 12

• October 10, 2013, Unit 1, turbine driven AFW pump testing in accordance with Procedure OPT-206A, "AFW System," Revision 29

• October 10, 2013, Unit 1, turbine driven AFW check valve reverse flow testing in accordance with Procedure OPT-530A, "AFW Check Valve Reverse Flow Test," Revision 4

• December 2, 2013, Unit 2, steam generator 2-01 atmospheric relief valve testing in accordance with Procedure OPT-504B, "MS Valve Testing," Revision 12 The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and components following testing.

The inspectors utilized Operating Experience Smart Sample (OpESS) FY2009-02, "Negative trend and Recurring Events Involving Feedwater Systems" during the performance of the inspections for the turbine driven auxiliary feedwater pump testing and check valve testing.

These activities constitute completion of four surveillance testing inspection samples (four routine surveillance testing samples) as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified. Cornerstone: Emergency Preparedness

1EP1 Drill Evaluation

a. Inspection Scope

The inspectors observed the biennial emergency plan exercise conducted October 9, 2013, to determine if the exercise acceptably tested major elements of the licensee emergency plan and provided opportunities to demonstrate key emergency response organization skills. The scenario simulated the following to demonstrate the licensee personnel's capability to implement their emergency plan:

• A ground-based attack on the plant protected area causing casualties among plant employees

• Damage to the auxiliary boiler fuel oil storage tank with burning fuel oil entering the protected area

• Catastrophic damage to two station transformers

• Damage to Unit 1 diesel generators, resulting in a loss of power to Unit 1 vital electric buses

• A loss of feedwater to Unit 1

• Damage to the waste gas decay tanks causing a radiological release to the environment

• An integrated law enforcement response to the licensee's site and activation of an incident command post The inspectors evaluated exercise performance by focusing on the risk-significant activities of event classification, offsite notification, recognition of offsite dose consequences, and development of protective action recommendations, in the control room simulator and the following emergency response facilities:

• Alternate Technical Support Center

• Alternate Operations Support Center

• Emergency Operations Facility

• Incident Command Post. The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of emergency workers, coordination of physical security arrangements between the site security organization and offsite law enforcement agencies, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensee's emergency response facilities, procedures for the performance of associated emergency functions, and other documents as listed in the attachment to this report. The inspectors compared the observed exercise performance with the requirements in the facility emergency plan, 10 CFR 50.47(b), 10 CFR Part 50, Appendix E, and with the guidance in the emergency plan implementing procedures and other federal guidance.

The inspectors reviewed previous drill and exercise scenarios to determine whether the licensee drill and exercise program preconditioned exercise participants. The inspectors also reviewed licensee drill and exercise evaluation reports against licensee performance during the October 9, 2013, exercise, to determine whether previously identified weaknesses had been corrected.

The inspectors attended the post-exercise critiques in the Technical Support Center and Emergency Operations Facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management.

These activities constitute completion of one drill evaluation sample as defined in Inspection Procedure 71114.01.

b. Findings

No findings were identified.

EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspectors performed an in-office review to verify the licensee had not submitted to the NRC during 2013 any changes to the licensee's emergency plan or emergency plan implementing procedures that required review according to the requirements of inspection procedure 71114.04. The inspectors did not identify any licensee documents requiring review. These activities constitute completion of one emergency action level and emergency plan changes sample as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation

a. Inspection Scope

The licensee submitted the preliminary scenario for the October 9, 2013, biennial exercise on August 1, 2013, in accordance with the requirements of Appendix E to 10 CFR 50, Part IV.F(2)(b). The inspectors performed an in-office review of the preliminary exercise scenario and evaluation objectives to determine if the exercise would acceptably test major elements of the emergency plan and provide opportunities to demonstrate key emergency response organization skills.

These activities constitute completion of one exercise evaluation sample as defined in Inspection Procedure 71114.08.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements

• ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements

• The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

• Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

• Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas by reviewing condition reports and performance audits

• Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one occupational ALARA planning and controls sample as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

The inspectors verified the accuracy and operability of the licensee's personnel monitoring equipment, verified the accuracy and effectiveness of the licensee's methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

• External dosimetry accreditation, storage, issue, use, and processing of active and passive dosimeters

• The technical competency and adequacy of the licensee's internal dosimetry program

• Adequacy of the dosimetry program for special dosimetry situations such as declared pregnant workers, multiple dosimetry placement, and neutron dose assessment

• Audits, self-assessments, and corrective action documents related to dose assessment since the last inspection These activities constitute completion of one occupational dose assessment sample as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensee's mitigating system performance index data for the period from the fourth quarter 2012 through the third quarter 2013 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, to determine the accuracy of the reported data.

These activities constituted completion of two mitigating system performance index residual heat removal systems samples as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensee's mitigating system performance index data for the period from the fourth quarter 2012 through the third quarter 2013 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, to determine the accuracy of the reported data. These activities constituted completion of two mitigating system performance index cooling water support systems samples as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors sampled licensee submittals for the drill and exercise performance, performance indicator for the period April 2012 through September 2013. The inspectors used definitions and guidance of Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, to determine the accuracy of the reported data. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predestinated control room simulator training sessions, performance during the 2013 biennial exercise, and performance during other drills.

These activities constitute completion of one drill/exercise performance sample as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors sampled licensee submittals for the emergency response organization drill participation performance indicator for the period April 2012 through September 2013. The inspectors used definitions and guidance of Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"

Revision 6, to determine the accuracy of the reported data. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, and exercise participation records.

These activities constitute completion of one emergency response organization drill participation sample as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Alert and Notification System (EP03)

a. Inspection Scope

The inspectors sampled licensee submittals for the alert and notification system performance indicator for the period April 2012 through September 2013. The inspectors used definitions and guidance of Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, to determine the accuracy of the reported data. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests.

These activities constitute completion of one alert and notification system sample as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review Inspection Scope The inspectors reviewed the licensee's corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety

issue. The inspectors focused on the safety-related procurement engineering program backlogs. The inspectors reviewed documents and interviewed personnel to determine if the licensee completely and accurately identified problems in a timely manner commensurate with its significance, evaluated and dispositioned operability issues, considered the extent of condition, prioritized the problem commensurate with its safety significance, identified appropriate corrective actions, and completed corrective actions in a timely manner commensurate with the safety significance of the issue. These activities constitute completion of one semi-annual trend review sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

The following activities constitute completion of four follow-up of events and notices of enforcement discretion samples as defined in Inspection Procedure 71153.

.1 (Closed) Licensee Event Report 05000445/2012-001-00, Unanalyzed Condition Discovered for the Normally Open Battery Room Fire and Cable Spread Room Doors Close on Momentary Loss of Power The inspectors reviewed the licensee event report that documented an issue where several battery room doors were held open with electromagnetic door devices.

Without an uninterruptible power to the door mechanisms, the doors would close in a loss of offsite power event. Inadvertent closure of the doors following a momentary loss of power prevents the doors from performing the hydrogen venting function and providing tornado venting pathways in the building. The licensee initiated compensatory measures to secure the doors in the open position and initiated a roving fire watch to comply with the fire protection function of the doors. The licensee replaced the batteries for the electromagnetic door devices and created a maintenance activity to ensure the doors devices operate as designed. The inspectors reviewed Condition Report CR-2012-0002186 that documented the issue and the work orders that corrected the issue. In addition, the inspectors reviewed the licensee's past operability evaluation.

The evaluation documented that the all structures, systems, and components remained operable for hydrogen generation and tornado venting concerns. The enforcement aspects of this finding are discussed in Section 4OA7. This licensee event report is closed.

.2 (Closed) Licensee Event Report 05000445/2012-002-00, Failure of Safety Related Breaker Control Devices due to a Common Cause The licensee event report documented failures of safety related 6.9 kV circuit breaker control devices.

The licensee hired a vendor to perform a failure analysis and the vendor concluded the failures of control devices were caused by a material weakness of the control device contact carrier frames as a result of a manufacturing defect. The licensee's corrective actions included the replacement of the potentially affected safety-related breaker control devices and the development of a receipt inspection testing criteria to be used for the control devices. The inspectors reviewed the licensee event report. No findings or violations of NRC requirements were identified. This licensee event report is closed.

.3 (Open) Units 1 and 2 Loss of Offsite Power to the Safety-Related 6.9 kV Buses and Notice of Enforcement Discretion 13-4-004

On December 4, 2013, the two required offsite circuits to both Units 1 and 2 safety-related 6.9 kV buses became inoperable during planned modification work to install an additional 138 kV transformer (XST1A). As a result of the event, the licensee declared an Unusual Event. The inspectors responded to the control room to access the operators' performance, procedure usage, and proper emergency plan declaration. The inspectors performed a walkdown of the control boards to verify appropriate equipment response following the loss of offsite power. The inspectors discussed the event with licensee personnel and the control room staff. Power was lost to the 345 kV transformer (XST2), which at the time was providing power to the 6.9 kV safeguards buses for both Units 1 and 2, when the licensee inadvertently cut into an energized 6.9 kV cable for transformer XST2, rather than the de-energized cable for transformer XST1. At 1:41 pm, both units entered Technical Specification 3.8.1, "AC Sources - Operating," Condition C, Required Action C.2, "restore one required offsite circuit to operable status" with a completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not met, then both units would be required to enter Condition G and be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The licensee requested a notice of enforcement discretion and an additional 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> to restore transformer XST1 or XST2, such that the completion time of Required Action C.2 would expire at 3:41 a.m. on December 6, 2013.

A notice of enforcement discretion was granted by the NRC staff at 1:00 p.m. on December 5, 2013. Consistent with NRC policy, the NRC agreed not to enforce compliance with the specific technical specifications in this instance, but will further review the cause(s) that created the apparent need for enforcement discretion to determine if there is a performance deficiency, if the issue is more than minor, or if there is a violation of requirements. This issue will be tracked as an unresolved item (URI)05000445/2013005-03; 05000446/2013005-03, "Notice of Enforcement Discretion 13-4-004 for a Loss of Both Required Offsite Power Circuits."

.4 Unit 2 Automatic Reactor Trip

a. Inspection Scope

On November 1, 2013, Unit 2 experienced an automatic reactor trip during a solid state protection system relay test. The inspectors responded to the control room to access the operators' performance and procedure usage. The inspectors performed a walkdown of the control boards to verify appropriate equipment response following the trip. The inspectors discussed the trip with operations management and the control room staff.

b. Findings

No findings were identified.

OA6 Meetings

Exit Meeting Summary

On August 29, 2013, the inspectors discussed the in-office review of the preliminary biennial exercise scenario with Mr. R. Kidwell, Manager, Emergency Preparedness, and other members of the licensee's staff. The licensee acknowledged the issues presented. On November 20, 2013, the inspectors presented the results of the onsite inspection of the licensee's emergency preparedness exercise conducted October 9, 2013, to Mr. T. McCool, Vice President, Station Support, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On December 17, 2013, the inspectors presented the radiation safety inspection results to Mr. T. McCool, Vice President, Station Support, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On December 31, 2013, the inspectors conducted a telephonic exit meeting with Ms. K. Faver, Manager, Emergency Preparedness, to verify that no changes to the licensee's emergency plan or implementing procedures requiring regulatory review according to the requirements of Inspection Procedure 71114.04 were submitted by the licensee between January and December 2013.

On January 6, 2014, the inspectors conducted a telephonic exit and presented the results of the licensed operator requalification program annual cycle inspection with Mr. G. Struble, Supervisor Operations Training. The inspectors did not review any proprietary information during this inspection. On January 9, 2014, the inspectors presented the resident inspection results to Mr. K. Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors acknowledged review of proprietary material during the inspection. No proprietary information was documented in the report.

4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC

Enforcement Policy for being dispositioned as a non-cited violation.

Title 10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable design bases requirements are translated into procedures. Contrary to the above, from 1989 until March 1, 2012, the licensee failed to assure that applicable design bases requirements were translated into procedures. Specifically, the licensee failed to assure preventative measures were established to ensure the electromagnetic door devices for the battery room and cable spreading room would maintain their function. The finding was more than minor because it was associated with design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating event to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," the inspector determined that the violation is of very low safety significance (Green) because the finding did not result in a loss of operability or functionality of a structure, system, or component. The violation was entered into the licensee's corrective action program as Condition Report CR-2012-0002186. This is the enforcement aspect of the licensee event report discussed in Section 4OA3.1.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Flores, Senior Vice President and Chief Nuclear Officer

K. Peters, Site Vice President

S. Bradley, Manager, Radiation Protection

D. Goodwin, Director, Work Management

T. Hope, Manager, Regulatory Affairs

K. Faver, Manager, Emergency Preparedness

F. Madden, Director, External Affairs

B. Mays, Vice President, Engineering

T. McCool, Vice President, Station Support

D. McGaughey, Director, Performance Improvement

B. Moore, Director, Nuclear Training

K. Nickerson, Director, Engineering Support

B. Patrick, Director, Maintenance

B. Reppa, Director, Site Engineering

S. Sewell, Plant Manager

M. Smith, Director, Nuclear Operations

K. Tate, Manager, Security

D. Wilder, Director, Plant Support

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000445/2013005-01 NCV Failure to Follow Instructions for Containment Sump Inspection Results in Debris Left in the Sump (Section 1R15)

05000445/2013005-02

05000446/2013005-02 FIN Cutting Incorrect Cable Results in an Inoperable Offsite Power Source (Section 1R18)

Opened

05000445/2013005-03

05000446/2013005-03 URI Notice of Enforcement Discretion 13-4-004 for a Loss of Both Required Offsite Power Circuits (Section 4OA3.3)

Closed

05000445/LER-2012-001-00 LER Unanalyzed Condition Discovered for the Normally Open Battery Room Fire and Cable Spread Room Doors Close on

Momentary Loss of Power (Section 4OA3.1)

05000445/LER-2012-002-00 LER Failure of Safety Related Breaker Control Devices due to a Common Cause (Section 4OA3.2)

Attachment 1

Section 1R01: Adverse Weather Protection

PROCEDURES NUMBER TITLE REVISION

ABN-912 Extreme Cold Weather/Heat Tracing and Freeze Protection System Malfunction 8

OWI-912 Cold Weather 4

STA-634 Extreme Temperature Equipment Protection Program 4

CONDITION REPORTS 2010-010887 2013-004679 2013-005262 2013-008066 2013-010305

WORK ORDERS

4202438

4435836

4582058

4687176

DRAWINGS NUMBER TITLE REVISION

MX-0225 Flow Diagram Fire Protection Treated Water Supply System, Sheet 7 16 M1-0233 Flow Diagram Station Service Water System 43 M1-0301 Flow Diagram Ventilation Containment, Sheet A 16 M2-0225 Flow Diagram Turbine Building Fire Protection, Sheet 1 14

M2-301 Flow Diagram Ventilation Containment, Sheet A 14

MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION

DBD-EE-045 Heat Tracing and Freeze Protection System 17

DBD-ME-228-01 Post-Accident Sampling System 7

Section 1R04: Equipment Alignment

CONDITION REPORTS 2012-013392

Attachment 1

PROCEDURES NUMBER TITLE REVISION

SOP-502B Component Cooling Water System 12

SOP-609B Diesel Generator System 13

Section 1R05: Fire Protection

DRAWINGS NUMBER TITLE REVISION E1-2021 Safeguard Building Fire Detection Plan

CP-3

M1-1921 Fire Hazard Analysis - Unit 1 Containment and Safeguards Buildings

CP-7

CALCULATIONS NUMBER TITLE REVISION 0210-063-0002 As-Built Combustible Loading Calculation Unit 1 Safeguards Building 14 0210-063-0011 Outside Areas As-Built Combustible Loading Calculation 7

PROCEDURES NUMBER TITLE REVISION

FPI-702 Fire Water Pumphouse 1

CONDITION REPORTS 2013-011468 2013-011825

Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance

MISCELLANEOUS DOCUMENTS Cycle 13-4 Cold Look, Simulator Evaluation Guide, LO47.D13.CLS Annual Operating Test Results dated January 2, 2014

Section 1R12: Maintenance Effectiveness

CONDITION REPORTS 2009-006993 2010-001395 2011-003128 2011-000524 2011-010074

Attachment 1

CONDITION REPORTS 2012-005740 2012-012280 2012-001233 2012-000342 2013-009033 2012-001233 2012-007856 2012-008354 2012-008050 2013-011449 2013-006476 2013-007686 2013-010351 2013-010578 2013-009549

MISCELLANEOUS DOCUMENTS NUMBER TITLE DATE 11-0524 Maintenance Rule Review Panel Meeting Minutes May 24, 2011

PROCEDURES NUMBER TITLE REVISION

STA-744 Maintenance Effectiveness Monitoring Program 6

WORK ORDERS 4318250

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

PROCEDURES NUMBER TITLE REVISION

STI-604.02 Maintenance Risk Assessment 0

CONDITION REPORTS CR-2013-010309

Section 1R15: Operability Evaluations and Functionality Assessments

PROCEDURES NUMBER TITLE REVISION

IST-101 Risk-Informed Inservice Testing 5

OPT-503A CNTMT ISOL Valves ASME Testing 14

STA-673 Station Layup Program 2

OPT-504B MS Valve Testing 12

IST-302 Inservice Testing of Power-Operated Valves 5

Attachment 1

MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION / DATE Approval of Risk-Informed Inservice Testing (RI-IST) Program for Comanche Peak Steam Electric Station, Units 1 and 2 August 14, 1998

Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 - Issuance of Amendment RE: Eliminate Requirements for Post-Accident Sampling System January 15, 2002LDCR

SA-2003-13 Revise FSAR Sections to Reflect Deletion of PASS from CPSES Licensing Basis and Status of System in the Plant November 5, 2003TXX-96371 Response to NRC Request for Additional Information on Risk-Based Inservice Testing (RBIST) June 3, 1996

TXX-97189 Response to NRC Request for Additional Information September 30, 1997

TXX-98134 Transmittal of Risk-Informed Inservice Testing Information Requested by NRC May 21, 1998

DBD-EE-045 Heat Tracing and Freeze Protection System 17

DBD-ME-228-01 Post-Accident Sampling System 7

DBD-ME-202 Main Steam, Reheat and Steam Dump System 23 2323-SS-15 Containment Personnel Air Lock Equipment Hatch and Emergency Air Lock 3 2323-MS-614 Technical Specification Pressure Gauges 1

DBD-CS-074 Containment Liner and Penetrations 8

DBD-ME-008 Containment Analysis 12

DBD-ME-028 Classification of Structures, Systems, and Components 23

FDA-2012-000230 Replace the IRC PAL and EAL pressure gauges 1

FDA-2012-000230 Replace the IRC PAL and EAL pressure gauges 3

VP-2013-0033 Verification Plan for Differential Pressure Gauge 0

VP-2013-0032 Verification Plan for Differential Pressure Gauge 1 6S852928 Procurement Review for Differential Pressure Gauge August 29, 2013 6S852930 Procurement Review for Differential Pressure Gauge September 4, 2013

Attachment 1

DRAWINGS NUMBER TITLE REVISION M1-2228, Sheet 3 Instrumentation & Control Diagram Process Sampling System Channel 4168, 4169, 4183 7 M1-2228, Sheet 5 Instrumentation & Control Diagram Process Sampling System Channel 4182 7 M1-2264, Sheet 10 Instrumentation & Control Diagram Liquid Waste Processing R.C. Drain Tank Subsystem Channel 7311, 7312 5 M1-2301, Sheet 8A Instrumentation & Control Diagram Ventilation-Containment Channel 5556, 5558, 5560 4 M2-0245 Flow Diagram Personnel Air Lock

CP-11

WORK ORDERS

3575400

3466960

3488234

3521078

3522902

3896937

3579104

3816742

3864298

3874495

4224346

3982877

4128583

4129852

4171129

4315901

4242188

4244839

4259056

4262677

4425701

4385151

4142049

3831125

3572337

4271392

4097231

4426605

4269660

4271384

4271397

CONDITION REPORTS 2013-011667 2013-011951 2013-011962 2013-011977 2013-000532 2013-012209 2013-012212 2011-005414 2013-005162 2013-008947 2013-008349

Section 1R19: Post-Maintenance Testing

PROCEDURES NUMBER TITLE REVISION

OPT-108A Remote Shutdown Instrumentation Check 8

OPT-112A Accident Monitoring Instrumentation Check 8

INC-201 Instrument Tubing and Supports Installation and Rework 4

INC-3016 Backfilling Process Sensors and Sensing Lines 3

INC-7420A Channel Calibration Steam Generator 1-04 auxiliary Feedwater Flow, Train B, Channel 2466A 4

Attachment 1

PROCEDURES NUMBER TITLE REVISION

SOP-103A Chemical and Volume Control System 18

INC-2085 Rework and Replacement of I&C Equipment 4

WORK ORDERS

4651089

4452162

4423823

4423855

4613467

4687821

4755621

4428485

4580087

4748256

4391729

CONDITION REPORTS 2013-010130 2010-011240 2013-001730 2013-012171 2013-011738

MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION

Post-Work Test Guide 12

Section 1R22: Surveillance Testing

PROCEDURES NUMBER TITLE REVISION

OPT-447B Mode 1, 3 and 4 Train A SSPS Actuation Logic Test 12

OPT-530A AFW Check Valve Reverse Flow Test 4

OPT-206A AFW System 29

OPT-504B MS Valve Testing 12

IST-302 Inservice Testing of Power-Operated Valves 5

WORK ORDERS

4625717

4661552

4691532

4682368

4695161

4425701

4097231

4142049

3831125

3572337

4426605

CONDITION REPORTS 2012-002034 2012-003307 2013-004927 2012-010272 2013-010413 2013-012209 2013-012212

Attachment 1

MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION

DBD-ME-202 Main Steam, Reheat and Steam Dump System 23

Section 1EP1: Exercise Evaluation

MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION / DATEEPP-109 Duties and Responsibilities of the Emergency Coordinator-Recovery Manager 14

EPP-116 Emergency Repair and Damage Control and Immediate Teams 7

EPP-201 Assessment of Emergency Action Levels, Emergency Classification and Plan Activation 12

EPP-201 EAL Technical Basis 0

EPP-203 Notifications 16

EPP-204 Activation and Operation of the Technical Support Center 15

EPP-205 Activation and Operation of the Operations Support Center 12

EPP-303 Operation of the Computer-Based Emergency Dose Assessment System 13

EPP-304 Protective Action Recommendations 21

ABN-015 Security Events 14

Green Team Graded Exercise Final Report November 18, 2013

Presentation Slides: Graded Exercise Results October 17, 2013

SG-021, Att 3.1 EOF Facility Critique Guideline 17

SG-021, Att 3.3 OSC Facility Critique Guideline 17

SG-021, Att 3.4 TSC Facility Critique Guideline 17

SG-021, Att 3.5 SIM/CR Facility Critique Guideline 17 Staff Guideline 19 Pre-Exercise and Post-Exercise Activities 25

CONDITION REPORTS 2013-010397 2013-010415 2013-010468 2013-010473 2013-010491 2013-010501 2013-010504 2013-010505 2013-010508 2013-011854 2013-011982 2013-011984 2013-011985 2013-011986 2013-011987

Attachment 1

Section 2RS2: Occupational

ALARA Planning and Controls

PROCEDURES NUMBER TITLE REVISION

RPI-606 Radiation Work and General Access Permits 28

RPI-629 Radiological Risk Management 3

STA-651 ALARA Program 11

STA-657 ALARA Job Planning/Debriefing 16

CONDITION REPORTS 2012-011018 2012-011034 2012-011708 2012-011969 2012-012232 2013-003697 2013-000922 2013-006228 2013-006231 2013-007176

2013-010468 2013-010722

MISCELLANEOUS DOCUMENTS NUMBER TITLE DATE

EVAL-2013-003 CPNPP Nuclear Oversight Evaluation Report June 13, 2013 2012-2016 CPNPP Five Year Dose Reduction Plan 2012-2016 January 19, 2012 RADIATION WORK PERMIT PACKAGES NUMBER TITLE REVISION

20122215 2RF13 Scaffold Activities 01

20122219 Rework of

2-8956B 04

20122600 2RF13 Westinghouse (WEC) Refueling Activities 01

20130229 Plant Electrical Modifications for

FDA 2010-172 03

20131215 1RF16 Scaffold Activities 01

20131600 1RF16 Westinghouse (WEC) Refueling Activities 01

Section 2RS4: Occupational Dose Assessment

PROCEDURES NUMBER TITLE REVISION

RPI-500 Bioassay Program 13

RPI-509 Personnel Dosimetry Processing Program 15

RPI-602 Air Sample Analysis 52

Attachment 1

PROCEDURES NUMBER TITLE REVISION

RPI-515 Neutron Dose Measurement

15

RPI-516 Dose Determination 25

STA-655 Declared Pregnant Worker 20

RPI-105 Exposure Records 21

CONDITION REPORTS 2012-007868 2012-007876 2012-010324 2013-010468 2013-012289

MISCELLANEOUS DOCUMENTS TITLE DATE Personnel Dosimetry Performance Testing: HPS N13.11-2001

November 7, 2011

NVLAP Accreditation Program July 2013

2RF1 3 Final Estimate versus Actual

EDEX Data 2013 1RF16 EDE Access Events and Final EDEX Dose 2013 Neutron Doses 2012-2013

Holtec DCS Neutron Data 2013

Response to ANI Information Bulletin 11-02, Neutron Monitoring August 2013

NVLAP On-Site Audit

Section 4OA1: Performance Indicator Verification

PROCEDURES NUMBER TITLE REVISION

EPP-201 Assessment of Emergency Action Levels, Emergency Classification and Plan Activation 12

EPP-203 Notifications 16

EPP-304 Protective Action Recommendations 21

Staff Guideline 20 NRC Performance Indicators 15

Section 4OA2: Problem Identification and Resolution

PROCEDURES NUMBER TITLE REVISION

ECE-6.02-06 Preparation of Verification Plans 7

Attachment 1

PROCEDURES NUMBER TITLE REVISION

ECE-6.02-02 Engineering Review of Procurement Documents 13

ECE-6.02-01 Procurement Levels 6

ECE-6.02 Engineering Processing of Procurement Documents 7

ECE-6.08 Determination of Shelf Life 3

ECE-6.02-05 Technical and Quality Assurance Requirements 9

CONDITION REPORTS 2009-004313 2010-003796 2011-001197 2012-003590 2012-009452 2013-001420

Attachment 2

REQUEST FOR INFORMATION - OCCUPATIONAL RADIATION SAFETY INSPECTION

The following items are requested for the occupational radiation safety inspection conducted the week of December 9, 2013.

Please provide the requested information on or before November 9, 2013.

Please submit this information using the same lettering system as below.

For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled "1- A," applicable organization charts in file/folder "1- B," etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.

Enter a note explaining in which file the information can be found.

If you have any questions or comments, please contact the lead inspector, Natasha Greene, at

(817)200-1154 or Natasha.Greene@nrc.gov.

Currently, the other inspector will be Louis Carson.

He may be contacted at (817)200-1221 or Louis.Carson@nrc.gov.

1.

Occupational ALARA Planning and Controls (71124.02) a. List of contacts and telephone numbers for ALARA program personnel b. Applicable organization charts

c. Copies of audits, self-assessments, and licensee event reports, written since date of last inspection, focusing on ALARA d. Procedure index for ALARA program

e. Provide specific procedures related to the following areas noted below.

Additional specific procedures may be requested by number after the inspector reviews the procedure indexes * ALARA program * ALARA committee * Radiation work permit preparation f. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the ALARA program.

In addition to ALARA, the summary should also address radiation work permit violations, electronic dosimeter alarms, and radiation work permit dose estimates.

Attachment 2

NOTE:

The lists should indicate the significance level of each issue and the search criteria used.

Provide documents which are searchable. g. List of work activities greater than 1 rem, since date of last inspection.

Include original dose estimate and actual dose

h. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of record) i. Outline of source term reduction strategy

2.

Occupational Dose Assessment (Inspection Procedure 71124.04) a. List of contacts and telephone numbers for dose assessment personnel

b. Applicable organization charts

c. Audits, self-assessments, vendor or NUPIC audits of contractor support, and licensee event reports written since date of last inspection, related to occupational dose assessment

d. Procedure indexes for occupational dose assessment

e. Provide specific procedures related to the following areas noted below.

Additional specific procedures will be requested by number after the inspector reviews the procedure indexes: * Radiation protection program * Radiation protection conduct of operations * Personnel dosimetry program * Radiological posting and warning devices * Air sample analysis * Performance of high exposure work * Declared pregnant worker * Bioassay program f. List of corrective action documents (including corporate and subtiered systems) written since date of last inspection, associated with: * NVLAP accreditation * Dosimetry (TLD/OSL, etc.) problems * Electronic alarming dosimeters * Bioassays or internally deposited radionuclides or internal dose * Neutron dose

NOTE:

The lists should indicate the significance level of each issue and the search criteria used g.

List of positive whole body counts since date of last inspection h.

Part 61 analyses/scaling factors