IR 05000333/2011002

IR 05000333-11-002, on 01/01/2011 - 03/31/2011, James A. FitzPatrick Nuclear Power Plant, Identification and Resolution of Problems

ML111240331
Person / Time
Site:	FitzPatrick
Issue date:	05/04/2011
From:	Mel Gray Reactor Projects Branch 2
To:	Bronson K Entergy Nuclear Northeast
Gray, Mel NRC/RGNI/DRP/PB2/610-337-5209
References
IR-11-002
Download: ML111240331 (24)

Text

with a copy to the Regional Administrator, Regionl

Office of Enforcement; U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001;and the NRC Senior Resident Inspector at FitzPatrick. In addition, if you disagree with thecross-cutting aspect assigned to the finding in this report, you should provide a response within30 days of the date of this inspection report, with the basis for your disagreement, to theRegionalAdministrator, Region l, and the NRC Senior Resident Inspector at FitzPatrick. ln accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure, and your response (if any) will be available electronically for public inspection inthe NRC Public Document Room or from the Publicly Available Records (PARS) component ofthe NRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp://www.nrc.gov/readinq-rmiadams.html (the Public Electronic Reading Room).

Sincerely,Docket No.:License No.:

Enclosure:

cc w/encl:rtl4"MMel Gray, ChiefProjects Branch 2Division of Reactor Projects50-333DPR-59I nspection Report 05000333/201 1 OO2

w/Attachment:

Supplemental I nformationDistribution via ListServ

SUMMARY OF FINDINGS

lR 0500033312011002:0110112011 - 0313112011; James A. FitzPatrick Nuclear Power Plant;ldentification and Resolution of Problems.The report covered a three-month period of inspection by resident inspectors and an announcedinspection by a region-based inspector. One Green finding, which was a non-cited violation,was identified. The significance of most findings is indicated by their color (Green, White,Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance DeterminationProcess" (SDP). The cross-cutting aspect for the finding was determined using IMC 0310,"Components Within the Cross-Cutting Areas." Findings for which the SDP does not apply maybe "Green" or be assigned a severity level after Nuclear Regulatory Commission (NRC)management review. The NRC's program for overseeing the safe operation of commercialnuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4,dated December 2006.

Cornerstone: Mitigating Systems

Green: The inspectors identified a non-cited violation (NCV) of very low safetysignriticance of 10 CFR 50, Criterion XVl, "Corrective Action," because Entergy personneldid not identify and correct a condition adverse to quality related to a control roomenvelope (CRE) boundary door. Specifically, Entergy personnel did not identify andimplement adequate actions to ensure the safety-related CRE boundary door, 70DOR-4-300-5, remained latched and able to perform its safety function. As corrective action,the foreign material that prevented the door from consistently latching was removed byEntergy personnel. The issue was entered into the corrective action program (CAP) ascondition reports CR-JAF-2010-08617 and CR-JAF-2011-00407'The finding was more than minor because it was associated with the configurationcontrol and the barrier performance attributes specific to the radiological barrier functionof the control room. The finding affected the Barrier Integrity cornerstone objective toprovide reasonable assurance that physical design barriers (fuel cladding, reactorcoolant system, and containment) protect the public from radionuclide releases causedby accidents or events. The finding was determined to be of very low safety significancein accordance with tMC 0609, Appendix A, "Determining the Significance of ReactorInspection Findings for At-Power Situations," based on a Phase 3 analysis. Theinspectors determined the period that the door was potentially open was small relative tothe technical specification (TS) allowed outage time, and therefore represented very lowsafety significance, considering the low probability of a design basis accident during thattime period.The finding had a cross-cutting aspect in the area of problem identification andresolution within the corrective action program component because Entergy personneldid not completely and accurately identify the degraded condition of the door (P.1(a) perIMC 0310). (Section 4OA2)

4

REPORT DETAILS

Summarv of Plant StatusThe James A. FitzPatrick Nuclear Power Plant (FitzPatrick) began the inspection periodoperating at 100 percent reactor power. On March 21 , operators reduced reactor power to 55percent ior a control rod sequence exchange, single control rod scram time testing, to identifyand plug main condenser tube leaks, and to repair a leak from the 'A' reactor feedwater pump.Operators restored reactor power to 100 percent on March 24. The plant continued to operateat or near full power for the remainder of the inspection period'1. REACTOR SAFEWCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R04 Equipment Aliqnment (71111.04).1 Quarterlv Partial Svstem Walkdown (71111.04Q - 4 samples)a. Inspection ScoPeThe inspectors performed four partial system walkdowns to verify the operability ofredundant or diverse trains and components during periods of system train unavailabilityor following periods of maintenance. The inspectors referenced system procedures, theupdated final safety analysis report (UFSAR), and system drawings in order to verify theaiignment of the available train was proper to support its required safety functions. Theinspectors also reviewed applicable condition reports (CRs) and work orders (WOs)toensure that Entergy personnel identified and properly addressed equipmentdiscrepancies that could impair the capability of the available equipment train, asrequired by Title 10, Code of Federal Regulations (10 CFR) Part _50, Appendix B,Criierion XVl, "Corrective Action." The documents reviewed are listed in the Attachment.The inspectors performed a partial walkdown of the following systems:. 'A' residual heat removal service water (RHRSW) when 'B' RHRSW was out ofservice for maintenance;o Reactor core isolation cooling (RCIC) when high pressure coolant injection (HPCI)was unavailable due to surveillance testing;. 'A' standby liquid control (SLC) while'B' SLC was out of service for maintenance;and. 'B'emergency service water (ESW) while 'A' ESW was out of service formaintenance.These activities constituted four partial system walkdown inspection samples.Enclosure 5b. FindinqsNo findings were identified..2 Complete Svstem Walkdown (71111.04S - 1 sample)a. Inspection ScopeThe inspectors performed a complete system alignment inspection of the HPCI systemto identify discrepancies between the existing equipment lineup and the required lineup.During the inspection, system drawings and operating procedures were used to verifyproper equipment alignment and operational status. The inspectors reviewed the openmaintenance WOs associated with the system for deficiencies that could affect the abilityof the system to perform its function. Documentation associated with unresolved designissues such as temporary modifications, operator workarounds, and items tracked byplant engineering were also reviewed by the inspectors to assess their collective impacton system operation. In addition, the inspectors reviewed the corrective action program(CAP) database to verify that equipment problems were being identified andappropriately resolved. The documents reviewed are listed in the Attachment.These activities constituted one complete system walkdown inspection sample.b. FindinqsNo findings were identified.

1R05 Fire Protection (71111.05)

.1 Quarterlv Review (71111.05Q - 5 samples)a. Inspection ScopeThe inspectors conducted inspections of fire areas to assess the material condition andoperational status of fire protection features. The inspectors verified, consistent withapplicable administrative procedures, that combustibles and ignition sources wereadequately controlled; passive fire barriers, manualfire-fighting equipment, andsuppression and detection equipment were appropriately maintained; and compensatorymeasures for out-of-service, degraded, or inoperable fire protection equipment wereimplemented in accordance with FitzPatrick's fire protection program. The inspectorsevaluated the fire protection program for conformance with the requirements of licensecondition 2.C(3), "Fire Protection." The documents reviewed are listed in theAttachment.r Turbine building miscellaneous oil storage room, fire arealzone lE/OR-3;. Reactor building (RB) 272 foot elevation, fire arealzone lX/RB-1A, XRB-18;. RB 300 foot elevation, fire arealzone Vlll/RB-1C, IXRB-1A, )URB1B;r East cable tunnel, fire arealzone ll/CT-2; and. Crescent area - west, fire arealzone XVlll/RB-1W'These activities constituted five quarterly fire protection inspection samples.Enclosure 6b.FindingsNo findings were identified.

1R06 Flood Protection Measures (71111.06 - 1 sample)a. Inspection ScopeThe inspectors conducted tours of the relay room to assess internal flooding protectionmeasures in that area. The inspectors reviewed selected risk significant plant designfeatures intended to protect the associated safety-related equipment from internalflooding events. The inspectors reviewed flood analysis and design documents,including the lndividual Plant Examination and UFSAR.These activities constituted one internalflood protection measures inspection sample.b. FindinqsNo findings were identified.1R11 Licensed Operator Requalification Proqram (71111.11Q - 1 sample)a. Inspection ScopeOn March 7, the inspectors observed licensed operator simulator training to assessoperator performance during a scenario to verify that crew performance was adequateand evaluators were identifying and documenting crew performance problems. Theinspectors evaluated the performance of risk significant operator actions, including theuse of emergency operating procedures. The inspectors assessed the clarity andeffectiveness of communications, the implementation of appropriate actions in responseto alarms, the performance of timely control board operation and manipulation, and theoversight and direction provided by the shift manager. Licensed operator training wasevalualed for conformance with the requirements of 10 CFR Part 55, "Operators'Licenses." The documents reviewed are listed in the Attachment.These activities constituted one quarterly operator simulator training inspection sample.b. FindinqsNo findings were identified.1R12 Maintenance Effectiveness (71111.12Q - 2 samples)a. Inspection ScoPeThe inspectors reviewed performance-based problems involving selected in-scopestructures, systems, or components (SSCs) to assess the effectiveness of themaintenance program. The reviews focused on the following aspects when applicable:Enclosure

o Proper maintenance rule scoping in accordance with 10 CFR 50.65;. Characterization of reliability issues;. Changing system and component unavailability;. 10 CFR 50.65 (aX1) and (a)(2) classifications;. ldentifying and addressing common cause failures;. Appropriateness of performance criteria for SSCs classified (aX2); anO. Adequacy of goals and corrective actions for SSCs classified (aX1).The inspectors reviewed system health reports, maintenance backlogs, andMaintenance Rule basis documents. The documents reviewed are listed in theAttachment. The following systems were selected for review.r High pressure coolant injection system; ando Automatic depressurization system.These activities constituted two quarterly maintenance effectiveness inspection samples.b. FindinqsNo findings were identified.

1R13 Maintenance RiskAssessments and EmerqentWork Control (71111.13 - 5 samples)a. lnspection ScopeThe inspectors reviewed maintenance activities to verify that the appropriate riskassessments were performed prior to removing equipment for work. The inspectorsreviewed whether risk assessments were performed as required by 10 CFR 50'65(a)(4),and were accurate and complete. When emergent work was performed, the inspectorsreviewed whether plant risk was promptly reassessed and managed. The documentsreviewed are listed in the Attachment. The reviews focused on the following activities:o The week of January 3, that included turbine valve testing, RCIC system quarterlysurveillance testing, chemical cleaning of safety related unit coolers in the westcrescent room, and emergent maintenance to troubleshoot failure of the RCIC steamadmission valve, 13MOV-131, to fully open on demand'. The week of January 31, that included 'A' and 'C' emergency diesel generator (EDG)monthly surveillance testing, 'A' residual heat removal (RHR) system quarterlysurveillance testing, and emergent maintenance to correct a malfunctioning computerposition indication for the 'A' to 'C' EDG cross-tie breaker, Tl-1Q504.o The week of February 14, that included 'B'and 'D' EDG monthly surveillance testing,'B' standby gas treatment system maintenance, 'B' station battery ventilationsubsystem maintenance, 'B' RHR and RHRSW systems quarterly surveillancetesting, and emergent maintenance to troubleshoot an unexpected two percentreduction in 'B' average power range monitor (APRM) indication.Enclosure

b.8The week of February 28, that included 'A' and 'C' EDG monthly surveillance testing,adjustment of the reactor power high limiter for the 'A' reactor water recirculationmotor-generator, 'A' SLC system quarterly surveillance testing, 'A' core spray systemquarterly surveillance testing, and maintenance on the'A' battery room ventilationsystem.The week of March 21, that included single control rod scram time testing, repair of aleak from the 'A' reactor feedwater pump, torus-to-drywell vacuum breaker qua(erlysurveillance testing, and troubleshooting to isolate a main generator field electricalground.

1R15 These activities constituted five maintenance risk assessments and emergent workcontrol inspection samples.FindinqsNo findings were identified.Operabilitv Evaluations (71111.15 - 5 samples)a. Inspection ScopeThe inspectors reviewed operability determinations to assess the acceptability of theevaluations; the use and control of applicable compensatory measures; and compliancewith technical specifications (TSs). The inspectors' reviews included verification that theoperability determinations were conducted as specified by EN-OP-104, "OperabilityDetermination Process." The technical adequacy of the determinations was reviewedand compared to the TSs, UFSAR, and associated design basis documents (DBDs).The inspection focused on the following operability reviews:r CR-JAF-2011-00747 concerning a temperature indicating switch, 92TlS-101A,associated with the 'A' EDG that was maintaining the room temperature at 90degrees Fahrenheit;e CR-JAF-2011-O}43zconcerning the'C'main steam line radiation monitor, 17RM-251C, with regard to TS-required channel check surveillance and irregular (spiking)indication;. CR-JAF-2011-00923 concerning the'B'APRM subsequent to a two percent drop inindicated level that had occurred in association with a power supply replacement for.A'APRM;r CR-JAF-2O11-00968 concerning the potential effect of a loss of temperaturemonitoring capability for control rod drive 46-19 on the insertion time for that controlrod; and. CR-JAF -2011-01230 concerning the effect of the 'A' reactor water recirculationmotor-generator high speed mechanical stop position with regard to core flowlimitations consistent with core operating limits report (COLR) assumptions withrespect to core thermal limits.These activities constituted five operability evaluation inspection samples.Enclosure

Ib. FindinqsNo findings were identified.

1R18 Plant Modifications (71111.18 - 2 samples)a. Inspection ScopeThe inspectors assessed the adequacy of the 10 CFR 50.59 evaluations for the followingtemporary and permanent modifications respectively. The inspectors' reviewsconsidered whether the installations were consistent with the modificationdocumentation, that the drawings and procedures were updated as applicable, and thatthe post-installation testing was adequate. The following reviews represented onetemporary modification inspection sample and one permanent modification inspectionsample:r Temporary modification of the 'A' battery room ventilation system for operation withsupply tan 72AHLJ-30A inoperable, in accordance with OP-59A, "Battery RoomVentilation;" and. EC 14122, "Modification to lmprove SRV [safety/relief valve] Reliability - Replace02RV-71 C, -71E, and -71F with Target Rock Three-Stage Safety/Relief Valves."b. FindinqsNo findings were identified.1R19 Post-Maintenance Testinq (71111.19 - 6 samples)a. lnspection ScopeThe inspectors reviewed post-maintenance test procedures and associated testingactivities for selected risk-significant mitigating systems to assess whether the effect ofmaintenance on plant systems was adequately addressed by control room andengineering personnel. The inspectors verified whether test acceptance criteria wereclelr, demonstrated operational readiness, and were consistent with DBDs; testinstrumentation had current calibrations, adequate range, and accuracy for theapplication; and tests were performed, as written, with applicable prerequisites satisfied'Upon completion, the inspectors verified whether equipment was returned to the properalignment necessary to perform its safety function. Post-maintenance testing (PMT) waseviluated for conformance with the requirements of 10 CFR 50, Appendix B, CriterionXl, "Test Control." The documents reviewed are listed in the Attachment. PMT activitiesassociated with the following work orders were reviewed:. WO 00228000, preventive maintenance on the'A' standby gas treatment system;o WO 00260774, replacement of 52STA, stationary auxiliary switch, within the 71-10504 cubicle, associated with the tie breaker of the 'A' and 'c' EDGs;. WO 52189872, replacement of relay 03A-K50 within the 09-28 panel, associatedwith rod sequence control logic;o WO 52189878, replacement of relay 03A-K60 within the 09-28 panel, associatedwith a group notch control insert block;Enclosure

10. WO 52192021-01, replacement of reactor protection system 81 logic relay 05A-K1048; andr WO 00271482-01, replacement a section of piping in the west crescent service watersupply to 'E' and 'G' unit coolers due to a pinhole leak'These activities constituted six PMT inspection samples.b. FindinosNo findings were identified.

4OA2 ldentification and Resolution of Problems (71152 - 1 sample)

.1 Review of ltems Entered into the Corrective Action Proqrama. Inspection ScoPeAs required by Inspection ProcedureTll52, "ldentifiCation and Resolution of Problems,"to identify rep-etitive equipment failures or specific human performance issues for follow-Enclosure b.11up, the inspectors performed a daily screening of all items entered into Entergy's CAP'The review was accomplished by accessing Entergy's computerized database for CRsand attending CR screening meetings. In accordance with the baseline inspectionprocedures, the inspectors selected items across the Initiating Events, MitigatingSystems, Barrier Integrity, and Public Radiation Safety cornerstones for additionalfottow-up and review. The inspectors assessed Entergy personnel's threshold forproblem identification, the adequacy of the cause analyses, and extent of conditionreview, operability determinations, and the timeliness of the specified corrective actions.The CRs reviewed are listed in the Attachment.Findinqs and Observationslntroduction: The inspectors identified an NCV of very low safety significance of 10 CFR50, Cnterion XVl, "Corrective Action," because Entergy personnel did not identify andcorrect a condition adverse to quality related to a control room envelope (CRE) boundarydoor. Specifically, Entergy personnel did not identify and implement adequate actions toensure the safety-related CRE boundary door, 70DOR-A-300-5, remained latched andable to perform its safety function.Description: During a system walkdown performed by Entergy pejs_onnel o.n December29;;019.2 systernengineer identified door 70DOR-A-300-5, a CRE boundary doorbetween the control room chiller room and the control room heating, ventilation, and airconditioning (HVAC) room, to be open and unlatched. The individual closed and latcheddoor 70DOR-n-SOO-S and initiated CR-JAF-2O10-08617. ln addition, the engineerdocumented within the condition report that the door seemed to require more force toshut than normal. After performing the daily review of condition reports the followingday, on December 30,2010, the inspectors performed a walkdown and identified door70bOR-A-300-5 unlatched and slightly ajar. After discovering the door unlatched andajar, the inspectors verified no Entergy personnelwere in the two rooms associated withdoor 70DOR-A-300-5, closed and latched the door, and notified control room personnelof the deficiency.Entergy personnel screened CR-JAF-2010-08617 to the significance level 'D -.ActionsTakeri'-and closed the CR on January 13,2011, with closure remarks stating that door70DOR-A-300-5 was secured closed and the Shift Manager was notified. Theinspectors concluded it would have been reasonable to more thoroughly investigate thephysical condition of the door at that time, given that there were two separate instancesin which door 70DOR-A-300-5 had been identified as unlatched.On January 21,2011, the inspectors identified door 70DOR-A-300-5 unlatched a thirdtime and noted that the door would, although visually appearing to be fully latched,intermittently fail to automatically latch and require more manual force to close thannormal. Eniergy personnel inspected door 70DOR-A-300-5 and identified a piece ofmetal foreign m-aterial protruding from the bottom of the door between laminate layers,which waslntermittentiy catching upon the ramped door sill and interfering with freeclosure of the door. Entergy personnel determined that the foreign material was mostlikely a remnant of the door shell that had fallen inside the door when a hole saw wasused to bore the holes for the installation of door knobs on May 12,2009, a correctiveaction associated with a prior NRC finding documented in inspection report05000333/2009-002.Enclosure 12In order for the control room emergency ventilation air system (CREVAS) subsystems tobe considered operable, the CRE boundary must be maintained such that the CREoccupant dose from a large radioactive release does not exceed the calculated dose inthe licensing basis consequence analyses for design basis accidents, and that CREoccupants are protected from hazardous chemicals and smoke. Door 70DOR-A-300-5must be closed and latched in order to maintain these conditions. Although procedureAP-19.18, "Control Room Envelope Habitability Program," allows intermittent opening ofthe CRE boundary under administrative controls, as permitted by a note included in TS9.7.3, the door's condition in this case was not controlled and its state was unknown andunreliable.Entergy's corrective actions included removing the foreign material and initiatingcondition reports CR-JAF-2O1 0-0861 7 and CR-JAF-2O11 -00407'Analysis: There was an NRC-identified performance deficiency in that Entergypersonnet did not promptly identify and correct a condition adverse to quality associatedwith CRE boundary door 70DOR-A-300-5. The finding was more than minor because itwas associated with the configuration control and the barrier performance attributesspeci1c to the radiological barrier function of the control room. The finding affected theBarrier Integrity corneistone objective to provide reasonable assurance that physicaldesign barriers (fuet cladding, reactor coolant system, and containment) protect thepublic from radionuclide releases caused by accidents or events.The finding was evaluated using Inspection Manual Chapter (lMC) 0609, "SignificanceDeterminalion Process," (SDP) Phase I and screened to a SDP Phase 3 review becausethe finding represented a degradation of the barrier function provided for the controlroor "gai-nst toxic atmosphere and smoke, as well as radiological conditio_ns' Based onsenior iisk analyst review, the finding was determined to be of very low safetysignificance (Gieen) because the amount of time the door was unlatched and ajar wastimiteO to 24 days. The mitigating actions immediately required by action statement B'1are required by B.2 to be verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to ensure CRE occupant exposures toradiological, chemical, and smoke hazards will not exceed limits. ln addition, action B'3to restolre the CRE boundary to operable status has a required completion time of 90days. Therefore, considering the allowed outage time of 90 days, the maximumpoientialtime of 24 days during which this condition existed, coupled with the lowprobability of a design basis aCcident during this time period, results in very low safetysignificance.The inspectors determined that this finding had a cross-cutting aspect in the area ofproblem identification and resolution within the corrective action program componentbecause Entergy personnel did not completely and accurately identify the degradedcondition of the door (P.1(a) per IMC 0310).Enforcement: 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, inpart, that, "t\4easures shall be established to assure that conditions adverse to quality,such as failures, malfunctions, deficiencies, deviations, defective material andequipment, and non-conformances are promptly identified and corrected." Contrary tothe above, between December 29,2010, and January 21, 2011, Entergy personnel didnot promptly identify and correct a condition adverse to quality associated with amaliunctionof CRE boundary door 70DOR-A-300-5. This resulted in short periods oftime where the CRE boundary was inoperable. Entergy took corrective actions toEnclosure

.213 remove interfering foreign material to improve the reliability of the door closure function.Because this violation was of very low safety significance and was entered into the CAPas CR-JAF-2011-00407, this violation is being treated as an NCV, consistent with theNRC Enforcement Policy. (NCV 05000333/2011002-01: Control Room Envelopelnoperable due to Unlatched Boundary Door)Annual Sample: Review of Continued Operabilitv of Liqhthouse Hill Substation 115 kVOffsite Power Line 3 (1 sample)Inspection ScopeThe inspectors selected CR-JAF-2005-00109 as a problem identification and resolutionsample for a detailed follow-up review. This CR documented Entergy personnel's reviewregarding whether the TRM may not have correctly reflected the plant licensing basisregarding the 1 15 kV systems as of January 11 ,2005. Offsite power to FitzPa_trick issupplied directly by Lighthouse Hill substation 1 15 kV line 3, and indirectly by SouthOswego substation 1 15 kV line 1 via Nine Mile Point - FitzPatrick tie line 4. A loss of line1 or 4 would require the Lighthouse Hill 1 15 kV line 3 to independently power bothreserve station service transformers (RSSTs) and their safety and house loads atFitzPatrick. However, under certain grid loading conditions with line 1 or 4 unavailable,line 3 alone may not provide adequate voltage. This CR was initiated by Entergypersonnel to determine operability of the Lighthouse Hill 1 15 kV offsite power line,concurrent with the loss of line 1 or 4, to ensure that voltage would stay within the motorstarting capability of FitzPatrick's 1 15 kV and 4 kV electric systems. Additionally,Entergy personnel initiated corrective actions to revise the necessary documents toensure operation of the line was consistent with the TS requirements and to makemodifications to FitzPatrick as necessary. This CR was initiated after an issue wasidentified on January 10,2005 (documented in CR-JAF-2005-00089), which determinedthat the plant had continued to operate on a single 1 15 kV offsite supply line (line 3) forgreater than the TS-allowed maximum of seven days, as documented in NRC inspectionieport 05000333/2004-005. FitzPatrick personnel performed several operabilityevaluations (CR-JAF-2005-00109) and determined that, through current operatorpractices, power monitoring actions, and load limitations, FitzPatrick 1 15 kV offsitecircuits are capable of supplying all engineered safeguard loads and performing theirintended functions in any configuration until long term corrective actions are completed'The inspectors assessed Entergy's problem identification threshold, apparent causeevaluation (ACE), extent of condition reviews, operability evaluations, and theprioritization and timeliness of corrective actions to determine whether Entergy wasappropriately identifying, characterizing, and correcting problems associated with theidentified issues and whether the planned or completed corrective actions wereappropriate to prevent recurrence. Additionally, the inspectors performed walkdowns ofaccessible portions of the 1 15 kV system and components to assess if abnormalconditions existed. The inspectors also interviewed plant personnel regarding theidentified issues and implemented or planned corrective actions. The documentsreviewed are listed in the Attachment.Findinqs and ObservationsNo findings were identified. The inspectors determined that Entergy personnel properlyimplemerited their CAP regarding the issue. The CR packages were complete andb.Enclosure

14included an ACE, operability evaluations, extent of condition reviews, use of operatingexperience, and contained implemented and planned corrective actions. Additionally,the elements of the CRs, ACE, and operability evaluations were detailed and thorough.lmplemented and planned corrective actions by Entergy personnelwere appropriate tominimize the potential of recurrence.The inspectors noted that corrective actions included revising the TS bases to revise thedefinition of qualified offsite circuits to include the 1 15 kV lines, revoking the appropriateTRM section for 115 kV lines being inoperable, and initiating CR-JAF-2005-00109 toperform operability evaluations of the 1 15 kV lines ability to supply adequate power tooperate safeguards equipment and house loads when the South Oswegosubstation/Nine Mile Point Unit 1 power source lines 1 or 4 are out-of-service. Theinspectors determined the additional corrective actions included performing severaloperability evaluations and engineering evaluations to ensure the offsite powercapabilities without lines 1 or 4 were adequate to supply power for a loss of coolantaccident; implementing an operating shift standing order to perform monitoring of the115 kV transmission system; establishing communication protocols between Nine MilePoint Unit 1, FitzPatrick, and the grid operator when a 115 kV line is out of service;revising the post contingency voltage alarm set-point from 1 12.5 kV to 1 12.0 kV(subsequently revised to 112.8 kV by further analysis in CR-JAF-2010-03421) tomaintain adequate voltage at the 4.16 kV emergency buses; and revising operationsprocedures to operate the 1 15 kV system within the licensing and design bases.The inspectors concluded that FitzPatrick personnel had conducted adequate operabilityevaluations, implemented appropriate agreements with grid operators and had adequateoperations procedures in place to provide proper monitoring, evaluation, and responsefor the 1 15 kV offsite power systems as issues occur. The inspectors determined theseactions appear adequate to ensure that the 1 15 kV offsite power lines remain capable ofperforming their safety function under the various scenarios analyzed.4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153 - 1 sample).1 (Closed) LER 05000333/2010005-00, High Pressure Goolant lnjection System Declaredlnoperable due to Power Supply DegradationOn October 23,2010, Entergy personnel identified a condition that could have preventedthe fulfillment of the safety function of the HPCI system, a system needed to removeresidual heat. Entergy staff noticed an acrid odor within the control room which wasdetermined to be emanating from 23lNV-79, the HPCI instrument power inverter.Entergy staff also noted that the casing of 23lNV-79 had a spot of discoloration fromapparent localized overheating. Based on these indications, Entergy personnel declaredthe HPCI system inoperable and implemented an engineering change to replace thedegraded inverter, a Topaz Electronics Model N250-GWR-125-60-115, with one of newdesign.Entergy personnel performed a visual inspection of the removed inverter's internalcomponents and noted heat and smoke damage associated with a transformer internalto the device. Based on the degraded material condition, Entergy staff considered theinverter to not be capabte of performing its safety function at the time of discovery. Thedegraded inverter was supplied to FitzPatrick in February 1973 and had beenrefurbished and reinstalled in the plant on October 1Q,2010. According to ElectricEnclosure 15Power Research lnstitute EL-5036, Volume 2, "Power Transformers," the typical lifeexpectancy of an energized and loaded transformer is between 30 and 40 years,However, transformers are generally considered beyond the usual scope of itemsreplaced during preventive maintenance refurbishments'The significance of the condition was mitigated by the fact that the automaticdepressurization,low pressure coolant injection, core spray, and RCIC systems wereavailable. Corrective actions documented in CR-JAF -201 0-07 341 includedimplementing a design change and replacing 23lNV-79 with a new model and initiatingwork orders to replace the remaining Topaz Electronics Model N250-GWR-125-60-115inverters installed in the plant with the new design. No violation of regulatoryrequirements occurred and no findings were identified. This LER is closed.4OAO Meetinos, Includinq ExitExit Meetinq SummarvThe inspectors presented the inspection results to Mr. B. Sullivan and other members ofEntergy's management at the conclusion of the inspection on April 27,2011. Theinspectors asked Entergy personnel whether any materials examined during theinspection should be considered proprietary. No proprietary information was identifiedby Entergy's personnel.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Enterqv Personnel

K. Bronson, Site Vice President

B. Sullivan, General Manager, Plant Operations

M. Woodby, Director, Engineering

B. Finn, Director, Nuclear Safety Assurance

C. Adner, Manager, Operations

J. LaPlante, Manager, Security

J. Barnes, Manager, Training and Development

T. Raymond, Manager, Project Management

M. Reno, Manager, Maintenance

C. Brown, Manager, Quality Assurance, Entergy

P. Cullinan, Manager, Emergency Preparedness

V. Bacanskas, Manager, Design Engineering

D. Poulin, Manager, System Engineering

P. Scanlan, Manager, Programs and Components Engineering

J. Pechacek, Manager, Licensing

E. Wolf, Manager, Radiation Protection

LIST OF ITEMS

OPEN, CLOSED, AND DISCUSSEDOpened and

Closed

05000333/LER-2011-002-01Closed05000333/201 0005-00Control Room Envelope Inoperable due toUnlatched Boundary DoorHigh Pressure Coolant Injection SystemDeclared Inoperable due to Power SupplyDegradationNCVLERDiscussedNoneAttachment

A-2

Section 1R04: Equipment AliqnmentProcedures:AP-17 .02, "Housekeeping and Cleanliness Control," Revision 18OP-17, "Standby Liquid Control System," Revision 48OP-21, "Emergency Service Water (ESW)," Revision 37OP-15, "High Pressure Coolant Injection," Revision 57Documents:DBD{23JDesign Basis Document for the High Pressure Coolant Injection System," Revision 11Section 1R05: Fire ProtectionProcedures:PFP+WR15, "Crescent Area - WesVElev . 227' , 242 Fue ArealZone

XVlll/RB-1W," Revision 3PFP-PWR47, "Foam & Miscellaneous Oil Storage Rooms/Elev.272' Fire ArealZone lE/OR-3,

FP-2," Revision 1pFP-PWR20, "Reactor Building - EasVElev.272' Fire ArealZone lX/RB-1A," Revision 4PFP-PWR21, "Reactor Building - WesUElev. 272' Fire ArealZone

XRB-1," Revision 4pFP-PWR24, "Reactor Building - EasUElev. 300' Fire ArealZone lX/RB-1A, Vlll/RB-1 C,"Revision 4pFP-PWR2S, "Reactor Building - WesVElev. 300' Fire ArealZone

XRB-18, Vlll/RB-1C,"Revision 3Documents:JAF-RPT-O4-00478, "JAF Fire Hazards Analysis," Revision 2JAF Safe Shutdown Analysis Report, Revision 1

Section 1R06: Flood Protection MeasuresProcedures:AOP-51, "Unexpected Fire Pump Start," Revision 5AOP-43, "shutdown from Outside the Control Room," Revision 34Documents:mf-npf-UuLTI-021 07, "lndividual Plant Examination," Revision 1Section 1R11: Licensed Operator Requalification ProqramProcedures:\CP-+Z :f eedwater Malfunction (Lowering Feedwater Flow)," Revision 1 2AOP-28, "Operation During Plant Fires," Revision 18AOP-1, "Reactor Scram," Revision 43EOP-2, "RPV Control," Revision 9Attachment

Injection System," Revision 6System Health Report, 23 High Pressure Coolant Injection, 3'o quarter 2010List of Risk Significant Systems, Structures, and Components based on 2010 PSA UpdateJAF-RPT-02-00030, "Maintenance Rule Basis Document / System 02-ADS0 / AutomaticDepressurization System," Revision 2EN-DC-204, "Maintenance Rule Scope and Basis," Revision 2ADS System Health Report for Third Quarter 2010SRV Leakage Status, dated January 20,2011JENG-g1-0i35, "Assessment of Corrective Actions for Safety Relief Valve Setpoint Drift," datedMarch 20,2001

Section 1R12: Maintenance EffectivenessProcedures:EN-DC-205, "Maintenance RuleOP-15, "High Pressure CoolantDocuments:A-3Monitoring," Revision 2Injection," Revision 57cR-JAF-2009-00285cR-JAF-2009-00286cR-JAF-2009-00350cR-JAF-2009-00382cR-JAF-2009-00384cR-JAF-2009-01265CR-JAF-2009-01398cR-JAF-2009-01407cR-JAF-2009-03055cR-JAF-2009-03073cR-JAF-2009-04256cR-JAF-2010-04721cR-JAF-2o10-07379DBD-023, "Design Basis Document for theJAF-RPT-H P Cl-02289, "Ma intena nce RuleCondition Reports:cR-JAF-2008-00537cR-JAF-2008-01309cR-JAF-2008-03193cR-JAF-2008-03231CR-JAF-2008-04718cR-JAF-2009-00200cR-JAF-2009-00206CR-JAF-2009-0021 1cR-JAF-20A9-A0212cR-JAF-2009-00230cR-JAF-2009-00243cR-JAF-2009-00267cR-JAF-2009-00284cR-JAF-2o10-07707cR-JAF-2010-08267CR-JAF-2O1

1-00132CR-JAF-201

1-0051 1High Pressure Coolant lnjection System," Revision 11Basis Document System 23 High Pressure CoolantCR-JAF-2009-01122cR-JAF-2o07-02937CR-JAF-2O10-00188cR-JAF-2010-00209CR-JAF-2010-01 138CR-JAF-2O10-03083cR-JAF-2010-05585CR-JAF-2010-07077cR-JAF-2o10-07095CR-JAF-2o10-07202CR-JAF-2010-07341cR-JAF-2o10-07348cR-JAF-2o10-07491Procedures:AP-05.13, "Maintenance During LCOs," Revision 9AP-10.10, "On-Line Risk Assessment," Revision 6AP-12.12, "Protected Equipment Program," Revision 9EN-WM-104, "On Line Risk Assessment," Revision 2Attachment

A-4Section 1 R1 5: Operabilitv EvaluationsProcedures:EN-OP-104, "Operability Determination Process," Revision 5EN-DC-126, "Engineering Calculation Process," Revision 4EN-LI-1 02" "Corrective Action Process," Revision 16ENN-lC-G-003, "lnstrument Loop Accuracy and Setpoint Calculation Methodology," Revision 0Documents:JAF-CArc-09-00002, "4KV Emergency Bus Degraded Voltage Time Delay Relay Uncertaintyand Set-point Calculation," Revision 1Condition Reports:cR-JAF-2o11-00270cR-JAF-2o10-06303

Section 1R18: Plant ModificationsProcedures:EN-DC-136, "Temporary Modifications," Revision 5EN-DC-115, "Engineering Change Process," Revision 10EN-DC-1 17, "Post Modification Testing and Special Instructions," Revision 3EN-Ll-1 00, "Process Applicability Determination," Revision 1 0Documents:@,.ModificationtolmproveSRVReliability'Replace02RV-71c,-71E,and71FwithTarget Rock Three-Stage Safety/Relief Valves (Model 0867F)," Revision 0EC 14122 Post Modification Test PlanEC 1412210

CFR 50.59 Screen

Section 1R19: Post Maintenance TestinqProcedures:tS-E-02, "lnstallation of Electrical Cable Terminations," Revision 13MP-054.02,"4.16 kV Bus and Metal-Clad Switchgear Maintenance," Revision 14ST-9BA, "EDG A and C Full Load Test and

ESW Pump Operability Test," Revision 12ST-34A, "PCIS Group 2 Logic Functional and Simulated Automatic Actuation Test," Revision 51ST-348; "Reactor Building Exhaust Rad Monitors InstrumenVLogic System Functional andSimulated Automatic Actuation Test," Revision 41lSp-1O0B-RPS, "RPS lnstrument FunctionalTesUCalibration (ATTS)**," Revision 34Documents:ST-9BA-1 10131 -52306 1 64Condition Reports:cR-JAF-2O11-01273CR-JAF-2o11-01274Attachment

A-5

Section 4OA2: ldentification and Resolution of ProblemsChanqe Requests:A4-044,

FSAR Change Request, "Define qualified Offsite Circuits as Required by TS," datedFebruary 3, 200505-001, TRM Change Request, "Delete TRM 3.8.C and corresponding bases based on theaddition of transmission lines #3 and #4 to the TS," dated January 14,200505-001, TS Bases Change Request, "Revise TS Bases 3.8.1 to add 1 15 kV transmission lines#3 and #4 to be part of the TS Qualified offsite circuits," dated January 14,2005Completed Surveillance Procedures:TST-129, "Post LOCA/Loss of Line #31#4 Contingency Voltage Verification," Revision 0,completed April 11, 2005Drawinqs:FE-1B, Main Line Diagram Station Service Transformers, Revision 13Niagara Mohawk Operating Diagram, Electrical System lnterconnection, Revision 2Enqineerinq Chanqes:EC l2l\3, "Replacement of Reserve Station Service TransformersTlT-2 and 71T-3," Revision 0EC 12703, "Post Modification Test Plan for RSST Replacement," Revision 0Enqineerinq Evaluations:@uitirye+skVBackfeedtoSatisfyTSReq.Remove115kVfromSerVice,',dated July 29,2004JAF-RPT-ELEC-04344,"115 kV Offsite Power Line Grid Voltage Regulation Study," Revision 2Condition Reports:cR-JAF-2005-00089cR-JAF-2005-00109CR-JAF-2010-03421oR-JAF-2010-08617CR-JAF-2011-00072CR-JAF-201

1-00086oR-JAF-201 1-001 14oR-JAF-2O11-00140cR-JAF-2011-00179oR-JAF-2011-00407CR-JAF-2011-00410oR-JAF-2011-00432CR-JAF-2011-00463cR-JAF-2011-00479oR-JAF-2O1

1-00511CR-JAF-201

1-00575CR-JAF-201

1-00596CR-JAF-201

1-00603CR-JAF-2011-00696CR-JAF-2O11-00711CR-JAF-201

1-00756oR-JAF-2011-00791CR-JAF-201

1-00863CR-JAF-201

1-00923CR-JAF-201

1-00930CR-JAF-201

1-00939CR-JAF-2O1

1-00968CR-JAF-2011-01121CR-JAF-2011-01147cR-JAF-2o11-01255oR-JAF-201

1-01256cR-JAF-2O11-01351CR-JAF-2O11-01439CR-JAF-2011-01510CR-JAF-201

1-01596Attachment

ACEADAMSAPRMCAPCFRCOLRCRCRECREVASDBDEDGEntergyESWFitzPatrickHPCIHVACrMcISTKVLERNCVNRCPARSPMTRBRCICRHRRHRSWRSSTSDPSLCSRVSSCSTTRMTSUFSARWOA-6

LIST OF ACRONYMS

apparent cause evaluationAgencywide Documents Access and Management Systemaverage power range monitorcorrective action programCode of Federal Regulationscore operating limits reportcondition reportcontrol room envelopecontrol room envelope ventilation air systemdesign basis documentemergency diesel generatorEntergy Nuclear Northeastemergency service waterJames

A. [[FitzPatrick Nuclear Power Planthigh pressure coolant injectionheating, ventilation, and air conditioninginspection manual chapterinservice testkilovoltlicensee event reportnon-cited violationNuclear Regulatory CommissionPublicly Available Recordpost-maintenance testingreactor buildingreactor core isolation coolingresidual heat removalresidual heat removal service waterreserve station service transformersignificance determination processstandby liquid controlsafety/relief valvestructure, system, or comPonentsurveillance testtechnical requirements manualtechnical specificationupdated final safety analysis reportwork orderAttachment]]