IR 05000237/2013003
| ML13219A080 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/06/2013 |
| From: | Patricia Pelke NRC/RGN-III/DRP/B6 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-13-003 | |
| Download: ML13219A080 (45) | |
Text
ust 6, 2013
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 NRC INTEGRATED INSPECTION REPORT 05000237/2013003; 05000249/2013003
Dear Mr. Pacilio:
On June 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Dresden Nuclear Power Station, Units 2 and 3. The enclosed report documents the results of this inspection, which were discussed on July 1, 2013, with Mr. D. Czufin, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
No findings were identified during this inspection.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Patricia J. Pelke, Acting Chief Branch 6 Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
Inspection Report 05000237/2013003; 05000249/2013003 w/Attachment: Supplemental Information
REGION III==
Docket Nos: 05000237; 05000249 License Nos: DPR-19; DPR-25 Report No: 05000237/2013003; 05000249/2013003 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Dates: April 1 through June 30, 2013 Inspectors: G. Roach, Senior Resident Inspector D. Meléndez-Colón, Resident Inspector T. Go, Health Physicist R. Walton, Senior Operator Licensing Examiner E. Sanchez Santiago, Reactor Inspector C. Phillips, Reactor Engineer D. Jones, Reactor Engineer J. Steffes, Reactor Engineer Approved by: Patricia J. Pelke, Acting Chief Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000237/2013003, 05000249/2013003; 04/01/2013 - 06/30/2013;
Dresden Nuclear Power Station, Units 2 and 3, Integrated Report.
This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. No findings were identified during this inspection.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings No findings were identified during this inspection.
Licensee-Identified Violations
No violations were identified.
REPORT DETAILS
Summary of Plant Status
Unit 2 On May 25, operators reduced power to approximately 62 percent electrical for planned turbine valve testing and control rod pattern adjustment. During the load reduction, newly identified work on turbine control valves was identified. The unit was limited to 90 percent power until the corrective maintenance on the control valves could be completed. On May 28, operators restored power to 100 percent.
Unit 2 operated at or near full power for the remainder of the reporting period.
Unit 3 On May 18, operators reduced power to approximately 64 percent power for planned turbine valve testing and control rod pattern adjustment. On May 19, operators returned the unit to full power operation.
Unit 3 operated at or near full power for the remainder of the reporting period.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:
- The coordination between the TSO and the plant during off-normal or emergency events;
- The explanations for the events;
- The estimates of when the offsite power system would be returned to a normal state; and
- The notifications from the TSO to the plant when the offsite power system was returned to normal.
The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:
- The actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;
- The compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;
- A re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and
- The communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.
Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures.
This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
.2 Readiness For Impending Adverse Weather Condition - Heavy Rainfall Conditions
a. Inspection Scope
The inspectors evaluated the design, material condition, and procedures for coping with the expected flooding conditions based on predicted rainfall and rises in local river and lake levels. The evaluation included a review to check for deviations from the descriptions provided in the Updated Final Safety Analysis Report (UFSAR) for features intended to mitigate the potential for flooding. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable.
Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site which would inhibit site drainage during the predicted flood conditions or allow water ingress past a barrier. The inspectors also walked down underground bunkers/manholes subject to flooding that contained multiple train or multiple function risk-significant cables. The inspectors also reviewed the abnormal operating procedure (AOP) and compensatory measures for mitigating the expected flooding conditions to ensure they could be implemented as written. Specific documents reviewed during this inspection are listed in the Attachment to this report.
This inspection constituted one readiness for impending adverse weather condition (heavy rainfall) sample as defined in IP 71111.01-05
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- Unit 2 Division I low pressure coolant injection (LPCI)/containment cooling service water (CCSW) during Division II LPCI/CCSW planned maintenance;
- Unit 2 high pressure coolant injection (HPCI) during isolation condenser (IC)out-of-service (OOS) for planned maintenance; and
- Unit 2 2B core spray during 2A core spray planned maintenance.
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization.
Documents reviewed are listed in the Attachment to this report.
These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- Fire Zone 18.6, Unit 2 125V Alternate Battery Room;
- Station Blackout Diesel Generator 3;
- Fire Zone 8.2.5E, Unit 3 Reactor Feed Pumps, Elevation 517; and
- Fire Zone 8.2.6A Unit 2 Switchgear Area, Elevation 534.
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.
Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.
Documents reviewed are listed in the Attachment to this report.
These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
.2 Annual Fire Protection Drill Observation
a. Inspection Scope
On April 17, 2013, the inspectors observed a fire brigade activation for Fire Area/
Zone 8.2.5A, Unit 2 track way area, elevation 517 feet. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:
- proper wearing of turnout gear and self-contained breathing apparatus;
- proper use and layout of fire hoses;
- employment of appropriate firefighting techniques;
- sufficient firefighting equipment brought to the scene;
- effectiveness of fire brigade leader communications, command, and control;
- search for victims and propagation of the fire into other plant areas;
- smoke removal operations;
- utilization of pre-planned strategies;
- adherence to the pre-planned drill scenario; and
- drill objectives.
Documents reviewed are listed in the Attachment to this report. These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding
.1 Underground Vaults
a. Inspection Scope
The inspectors selected underground bunkers/manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors determined that the cables were not submerged, that splices were intact, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as a sump pump, the device was operable and level alarm circuits were set appropriately to ensure that the cables would not be submerged. In those areas without dewatering devices, the inspectors verified that drainage of the area was available, or that the cables were qualified for submergence conditions. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following underground bunker/manhole subject to flooding:
- Station blackout, manhole number 1 Specific documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one underground vaults sample as defined in IP 71111.06-05.
b. Findings
No findings were identified.
1R07 Annual Heat Sink Performance
.1 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the licensees testing of the 2B low pressure coolant injection heat exchanger to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed for this inspection are listed in the Attachment to this document.
This annual heat sink performance inspection constituted one sample as defined in IP 71111.07-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On May 8, 2013, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
a. Inspection Scope
On May 19, 2013, the inspectors observed Unit 3 ten percent scram timing. Then, on May 29, 2013, the inspectors observed Unit 3 operators restart the reactor water clean-up system following a trip due to failed temperature switch. These were activities that required heightened awareness or were related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly licensed operator heightened activity/risk samples as defined in IP 71111.11.
b. Findings
No findings were identified.
.3 Biennial Written and Annual Operating Test Results
a. Inspection Scope
The inspectors reviewed the overall pass/fail results of the Biennial Written Examination, and the Annual Operating Test administered by the licensee from April 17, 2013, through May 24, 2013, as required by 10 CFR 55.59(a). On May 28, 2013, the inspector received and reviewed the results of the annual operating test. The results were compared to the thresholds established in Inspection Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP)," to assess the overall adequacy of the licensees LORT Program to meet the requirements of 10 CFR 55.59. (Section 02.02)
This inspection constituted one annual licensed operator requalification examination results sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
.4 Biennial Review
a. Inspection Scope
The following inspection activities were conducted during the week of May 13, 2013, to assess: 1) the effectiveness and adequacy of the facility licensees implementation and maintenance of its Systems Approach to Training (SAT) based Licensed Operator Requalification Training (LORT) Program, put into effect to satisfy the requirements of 10 CFR 55.59. The documents reviewed are listed in the Attachment to this report.
- Licensee Requalification Examinations (10 CFR 55.59(c); SAT Element 4 as Defined in 10 CFR 55.4): The inspectors reviewed the licensees program for administration of the LORT annual operating tests to assess the licensees ability to develop and administer examinations that are acceptable for meeting the requirements of 10 CFR 55.59(a).
The inspectors observed the administration of the annual operating test to assess the licensees effectiveness in conducting the examinations, including the conduct of evaluations of individual operator and crew performance, and post-examination analysis. The inspectors evaluated the performance of one crew in parallel with the facility evaluators during two dynamic simulator scenarios. (Section 02.05)
- Problem Identification and Resolution (10 CFR 55.59(c); SAT Element 5 as Defined in 10 CFR 55.4): The inspectors assessed the licensees ability to identify, evaluate, and resolve problems associated with licensed operator performance (a measure of the effectiveness of its LORT program and their ability to implement appropriate corrective actions to maintain its LORT program up-to-date). The inspectors reviewed documents related to licensed operator performance issues (e.g., licensee event reports; licensee condition/problem identification reports including documentation of plant events and review of industry operating experience).
(Section 02.10)
This inspection constituted one Biennial Licensed Operator Regulation Program sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- Miscellaneous Sumps and Drains (Maintenance Rule Function Z49); and
- Main Turbine and Auxiliaries (Maintenance Rule Function Z56).
The inspectors reviewed events such as where ineffective equipment maintenance had or could have resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 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:
- Unit 2 Yellow Risk due to 2A instrument air compressor (IAC) and U2 service air to instrument air crosstie out-of-service (OOS) for the replacement of the 2A instrument air receiver outlet valve;
- Unit 3 Yellow Risk during Division I and II LPCI injection emergency core cooling system (ECCS) initiation logic system functional test (LSFT);
- Unit 3 Yellow Risk due to LPCI loop select LSFT and Unit 2 Yellow Risk due to isolation condenser OOS for planned maintenance; and
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Specific documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- U3 DIV II CCSW Pipe Code Class III repair;
- IR 1516289, Incorrect Quality Level Part Used in Safety Related Valve; and
- IR 1526426, 3-1501-5A Will Not Close from control room.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
This operability inspection constituted five samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modification(s):
- 2/3 diesel generator cooling water piping tie-in to fire protection header.
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system(s). The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.
This inspection constituted one permanent plant modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- Unit 2 Division II LPCI/CCSW planned maintenance;
- Unit 2 Station Blackout Diesel Generator planned maintenance;
- Unit 2 Isolation Condenser planned maintenance;
- Unit 2 A Core Spray Keep Fill Stop Valve Replacement; and
- Unit 2/3 B Control Room Emergency Ventilation System (CREVS).
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted five post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- WO 1434073, D3 2Y TS CS [core spray] Pump Comp Test with Torus Avail for IST [in-service testing] Surv;
- WO 01604908, D2 Quarterly TS Electromatic/Target Rock Relief Valves:
Pressure Switch Calibration and Functional Check; (routine)
- WO 01441941, D3 24M TS Div 1 & 2 LPCI ECCS Loop Select Circuitry LSFT; (routine)
- WO 01432041; D3 24M TS PCIS [primary containment isolation system] Group IV Isolation (HPCI) LSFT; (routine) and
- WO 01624793, D2 QTR TS HPCI STM Line Hi Flow ISOL MTU FUNCT (routine).
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the UFSAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted four routine surveillance testing samples, and one inservice testing sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Training Observation
a. Inspection Scope
The inspector observed a simulator training evolution for licensed operators on May 22, 2013, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.
This inspection of the licensees training evolution with emergency preparedness drill aspects constituted one sample as defined in IP 71114.06-06.
b. Findings
No findings were identified.
RADIATION SAFETY
2RS2 Occupational As-Low-As-Is-Reasonably-Achievable (ALARA) Planning and Controls
The inspection activities supplement those documented in NRC Inspection Report 05000237/2012005; 05000249/2012005 and constitute one complete sample as defined in IP 71124.02-05.
.1 Radiological Work Planning (02.02)
a. Inspection Scope
The inspectors assessed whether the licensees planning identified appropriate dose mitigation features; considered alternate mitigation features; and defined reasonable dose goals. The inspectors evaluated whether the licensees ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment (e.g., ice vests). The inspectors determined whether the licensees work planning considered the use of remote technologies (e.g., teledosimetry, remote visual monitoring, and robotics) as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration of ALARA requirements into work procedure and radiation work permit documents.
The inspectors compared the results achieved (dose rate reductions, person-rem used)with the intended dose established in the licensees ALARA planning for these work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the actual work activity time requirements, and evaluated the accuracy of these time estimates.
The inspectors assessed the reasons (e.g., failure to adequately plan the activity, failure to provide sufficient work controls) for any inconsistencies between intended and actual work activity doses.
b. Findings
No findings were identified.
.2 Verification of Dose Estimates and Exposure Tracking Systems (02.03)
a. Inspection Scope
The inspectors reviewed the assumptions and basis (including dose rate and man-hour estimates) for the current annual collective exposure estimate for reasonable accuracy for select ALARA work packages. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and the intended dose outcome.
The inspectors evaluated whether the licensee had established measures to track, trend, and if necessary, to reduce occupational doses for ongoing work activities. The inspectors assessed whether trigger points or criteria were established to prompt additional reviews and/or additional ALARA planning and controls.
The inspectors evaluated the licensees method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered.
The inspectors assessed whether adjustments to exposure estimates (intended dose)were based on sound radiation protection and ALARA principles or if they were just adjusted to account for failures to control the work. The inspectors evaluated whether the frequency of these adjustments called into question the adequacy of the original ALARA planning process.
b. Findings
No findings were identified.
.3 Problem Identification and Resolution (02.06)
a. Inspection Scope
The inspectors evaluated whether problems associated with ALARA planning and controls are being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program
This inspection constituted one complete sample as defined in IP 71124.07-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the annual radiological environmental operating reports and the results of any licensee assessments since the last inspection to assess whether the Radiological Environmental Monitoring Program was implemented in accordance with the Technical Specifications and Offsite Dose Calculation Manual. This review included reported changes to the Offsite Dose Calculation Manual with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, Inter-Laboratory Comparison Program and Analysis of Data.
The inspectors reviewed the Offsite Dose Calculation Manual to identify locations of environmental monitoring stations.
The inspectors reviewed the Final Safety Analysis Report for information regarding the environmental monitoring program and meteorological monitoring instrumentation.
The inspectors reviewed quality assurance audit results of the program to assist in choosing inspection smart samples and audits and technical evaluations performed on the vendor laboratory program.
The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine if the licensee was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.
b. Findings
No findings were identified.
.2 Site Inspection (02.02)
a. Inspection Scope
The inspectors walked down select air sampling stations and optically stimulated luminescence dosimeter monitoring stations to determine whether they were located as described in the Offsite Dose Calculation Manual and to determine the equipment material condition. Consistent with smart sampling, the air sampling stations were selected based on the locations with the highest X/Q, D/Q wind sectors, and optically stimulated luminescence dosimeters were selected based on the most risk significant locations (e.g., those that have the highest potential for public dose impact).
For the air samplers and optically stimulated luminescence dosimeters selected, the inspectors reviewed the calibration and maintenance records to evaluate whether they demonstrated adequate operability of these components. Additionally, the review included the calibration and maintenance records of select composite water samplers.
The inspectors assessed whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station.
The inspectors observed the collection and preparation of environmental samples from different environmental media (e.g., ground and surface water, milk, vegetation, sediment, and soil) as available to determine whether environmental sampling was representative of the release pathways as specified in the Offsite Dose Calculation Manual and if sampling techniques were in accordance with procedures.
Based on direct observation and review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the Final Safety Analysis Report, NRC Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments in the control room and, if applicable, at the tower were operable.
The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, inoperable sampler, lost optically stimulated luminescence dosimeter, or anomalous measurement to determine whether the licensee identified the cause and whether they implemented corrective actions. The inspectors reviewed the licensees assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection)and reviewed the associated radioactive effluent release data that was the source of the released material.
The inspectors selected structures, systems, or components that involve or could reasonably involve licensed material for which there is a credible mechanism for licensed material to reach ground water, and assessed whether the licensee had implemented a Sampling and Monitoring Program sufficient to detect leakage of these structures, systems, or components to ground water.
The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.
The inspectors reviewed any significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection. They reviewed technical justifications for any changed sampling locations to evaluate whether the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.
The inspectors assessed whether the appropriate detection sensitivities with respect to Technical Specifications/Offsite Dose Calculation Manual where used for counting samples (i.e., the samples meet the Technical Specifications/Offsite Dose Calculation Manual required lower limits of detection). The licensee uses a vendor laboratory to analyze the Radiological Environmental Monitoring Program samples so the inspectors reviewed the results of the vendors Quality Control Program, including the inter-laboratory comparison, to assess the adequacy of the vendors program.
The inspectors reviewed the results of the licensees Inter-laboratory Comparison Program to evaluate the adequacy of environmental sample analyses performed by the licensee. The inspectors assessed whether the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility. If applicable, the inspectors reviewed the licensees determination of any bias to the data and the overall effect on the radiological environmental monitoring program.
b. Findings
No findings were identified.
.3 Identification and Resolution of Problems (02.03)
a. Inspection Scope
The inspectors assessed whether problems associated with the Radiological Environmental Monitoring Program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees Corrective Action Program. Additionally, they assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the radiological environmental monitoring program.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
4OA1 Performance Indicator (PI) Verification
.1 Safety System Functional Failures
a. Inspection Scope
The inspectors sampled licensee submittals for the Safety System Functional Failures (MS05) performance indicator for Dresden Nuclear Power Station Units 2 and 3 covering the period from the second quarter 2012 through first quarter 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports and NRC Integrated Inspection Reports for the period of second quarter 2012 through first quarter 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two safety system functional failures samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index - Emergency AC Power System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC Power System (MS06) performance indicator for Dresden Nuclear Power Station Units 2 and 3 covering the period from the second quarter 2012 through first quarter 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, were used. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection Reports for the period of second quarter 2012 through first quarter 2013 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.
This inspection constituted two MSPI emergency AC power system samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance Index - High Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems (MS07) performance indicator for Dresden Nuclear Power Station Units 2 and 3 covering the period from the second quarter 2012 through first quarter 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the period of second quarter 2012 through first quarter 2013 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.
This inspection constituted two MSPI high pressure injection system samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.4 Reactor Coolant System Specific Activity
a. Inspection Scope
The inspectors sampled licensee submittals for the reactor coolant system specific activity PI for Dresden Nuclear Power Station Units 2 and 3 for the period from the first quarter 2012 through the first quarter 2013. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees reactor coolant system chemistry samples, Technical Specification requirements, issue reports, event reports, and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted two reactor coolant system specific activity samples as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
.3 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds (OWAs) on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.
The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment to this report were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP and proposed or implemented appropriate and timely corrective actions which addressed each issue.
Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.
This review constituted one OWA annual inspection sample as defined in IP 71152-05.
b. Findings
No findings were identified.
.4 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of January 2013 through June 2013, although some examples expanded beyond those dates where the scope of the trend warranted. The inspectors focused on the area of work planning.
The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.
This review constituted a single semi-annual trend inspection sample as defined in IP 71152-05.
b. Findings
No findings were identified.
.5 Selected Issue Follow Up Inspection: Unit 3 Turbine Oil Reservoir Deluge System
Actuation
a. Inspection Scope
During a review of items entered in the licensees CAP, the inspectors recognized a corrective action item documenting the actuation of the Unit 3 turbine oil reservoir deluge system. The inspectors reviewed the troubleshooting activities and equipment repairs, as documented in Issue Report 1515926, U3 TURB OIL RES DELUGE ACTUATED, to verify that the licensee was appropriately addressing the issue in their corrective action program.
This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.
b. Observations On May 20, 2013, the following alarms were received in the main control room:
- 923-1 G-4, U2/3 Diesel Fire PP Running
- XL3 Device 21-19, 3TB 534 Turb Oil Resv Fire
- XL3 Device 21-09, 3TB 534 Turb Oil Resv Water Flow The Incident Commander and Equipment Operator were dispatched and reported there was neither fire nor personnel at the Unit 3 turbine oil reservoir. They also found the local pull box, 3-4141-106, actuated and no sign of fire present.
The Unit 3 turbine oil reservoir deluge system has automatic and manual actuation functions. The automatic actuation is initiated by any one of six fire protection devices feeding Terminal Board 2 in the 3-2253-43 panel, Local Turbine Oil Tank Fire Panel.
The manual actuation is initiated using the local pull box, 3-4141-106.
Upon arriving to the scene, Operations personnel found the local pull box with its cover open. The pull box showed signs of damage to the cover, which holds a spring loaded button in place. When the spring loaded button is released, a manual initiation signal is received at the local fire panel and the deluge system is actuated. A label on the inside of the pull box states: CAUTION: Excessive Tightening of Allen Head Screw to Back Plate Could Cause Undetectable Housing Fracture Resulting in a False Alarm.
Engineering concluded that the Allen screw was tightened excessively, causing the pull box to fail and leading to an actuation of the Unit 3 turbine oil deluge system. The licensee classified the pull box as run-to-failure, therefore there was no maintenance associated with this component. This same type pull box is used extensively throughout the plant. The licensee generated issue report (IR) 1515929, U3 TURB OIL RES DELUGE ACTUATED, to address the event.
The inspectors requested from the licensee the vendor information for this manual pull box. The licensee was not able to find any vendor related information on this specific component. The inspectors referenced procedure CC-AA-204, Control of Vendor Equipment Manuals, Revision 9. Per CC-AA-204, commercial, off-the shelf products/items that are typically run-to-failure need only to be included in the Vendor Manual Program at the Site Engineering Directors discretion. Per the Site Engineering Director, these pull boxes are not included in the Vendor Manual Program.
The inspectors reviewed procedure DFPS 4134-07, Unit 3 Turbine Oil Reservoir Deluge System Test, Revision 16. Steps I.4.a. and I.4.b. of DFPS 4134-07 test the remote actuation pushbutton of the Unit 3 turbine oil reservoir deluge system by removing the cover from the manual pull box, 3-4141-106, and verifying that the SOLENOID ACTIVATED red lamp and the MANUAL STATION ACTUATED red lamp illuminate and the local panel alarm and the XL3 alarm 21-19 are received. Step I.4.c. directs the operator to replace the cover on local manual station 3-4141-106. The inspectors noticed that no note or precaution was in the procedure to caution the operators about avoiding excessive tightening of allen head screw to the back plate due to the potential to cause housing fracture.
The inspectors also reviewed work order (WO) 1416070, D3 18M TSTR/COM TURBINE OIL RESERVOIR DELUGE SYS TEST, performed on July 14, 2012.
The licensee did not identify any issues during the performance of this surveillance.
The inspectors learned that in April 2013, the licensee received a notification from Honeywell Fire Systems addressing potential issues that could affect the normal operation of BG-10 series pull stations distributed under multiple brands including Fire-Lite Alarms, like the one in use at the Unit 3 turbine oil deluge system. Honeywell recommended that these pull stations should be inspected for cracking/fracturing of the plastic housing or bending of the pull station back plate. Any pull station showing signs of cracking of the housing or bending of the back plate should be replaced.
The inspectors questioned the licensee about what actions were taken or were planned to be taken to address the notification from Honeywell Fire Systems. After further conversations with the licensee the inspectors learned that no actions were taken or were planned to be taken to address the vendors notification.
The inspectors reviewed procedure LS-AA-115-1003, Processing of Level 3 OPEX
[operating experience] Evaluations, and determined that the notification from Honeywell met the definition of a Level 3 OPEX and therefore should have been treated as one.
Per LS-AA-115-1003, the licensee has 60 days to complete a formal Level 3 OPEX evaluation; since less than 60 days had passed since receipt of the vendors notification the inspectors treated this issue as a minor performance deficiency. The licensee generated issue report 1533868, Disposition of Vendor Information, to address the inspectors concerns. As part of the extent of condition the licensee identified six additional pull boxes subject to the same type of failure.
4OA5 Other Activities
.1 Temporary Instruction (TI) -2515/182 - Review of the Industry Initiative to Control
Degradation of Underground Piping and Tanks (Closed)
a. Inspection Scope
Leakage from buried and underground pipes has resulted in ground water contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, Nuclear Energy Institute (NEI) 09-14, Guideline for the Management of Buried Piping Integrity, (ADAMS Accession Number ML103090142) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession Number. ML110700122), with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued TI-2515/182, Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, to gather information related to the industrys implementation of this initiative.
From May 6 to May 10, 2013, the inspectors conducted a review of records and procedures related to the licensees program for buried pipe, underground pipe, and tanks in accordance with Phase II of TI-2515/182. This review was done to confirm that the licensees program contained attributes consistent with Sections 3.3 A and 3.3 B of NEI 09-14 and to confirm that these attributes were scheduled and/or completed by the NEI 09-14 Revision 1 deadlines. To determine whether the program attribute was accomplished in a manner which reflected good or poor practices in program management, the inspectors interviewed licensee staff responsible for the Buried Pipe Program. Additionally, the inspectors performed a walkdown of rectifiers, used for the operation and maintenance of the Cathodic Protection System and observed excavation of buried piping in preparation for testing.
Based upon the scope of the review described above, Phase II of TI-2515/182 was completed.
b. Observations The licensees Buried Piping and Underground Piping and Tanks Program was inspected in accordance with Paragraph 03.02.a of the TI and it was confirmed that activities which correspond to completion dates specified in the program which have passed since the Phase I inspection was conducted, have been completed. Additionally, the licensees Buried Piping and Underground Piping and Tanks Program was inspected in accordance with Paragraph 03.02.b of the TI and responses to specific questions found in http://portal.nrc.gov/edo/nrr/dirs/irib/Inspection%20Manual%20Forms%20Templates%20 s/Forms/AllItems.aspx, was submitted to the NRC Headquarters staff.
c. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On July 1, 2013, the inspectors presented the inspection results to Mr. D. Czufin, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The inspection results for the areas of occupational as-low-as-reasonably-achievable (ALARA) planning and controls; radiological environmental monitoring; and RCS specific activity performance indicator verification with Mr. S. Marik, Plant Manager, on May 24, 2013.
- On May 17, 2013, the inspectors presented inspection results of the Biennial Written and Annual Operating Test and Biennial Review to Mr. P. DiGiovanna and other members of the licensee staff. The licensee acknowledged the issues presented.
- The Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (TI-2515/182) with the Plant Manager, Mr. S. Marik and other members of the licensee staff on May 10, 2013.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Czufin, Site Vice President
- S. Marik, Station Plant Manager
- D. Anthony, NDES Manager
- J. Biegelson, Engineering
- H. Bush, Radiation Protection Manager
- J. Cady, Radiation Protection Manager
- P. Chambers, Dresden Licensed Operator Requalification Training Lead
- P. DiGiovanna, Training Director
- P. DiSalvo, GL 89-13 Program Owner
- H. Dodd, Regulatory Assurance Manager
- D. Doggett, Emergency Preparedness Manager
- J. Fox, Design Engineer
- J. Freeman, Corporate Engineering
- G. Gates, Operations
- D. Glick, Radioactive Material Shipping Specialist
- G. Graff, Nuclear Oversight Manager
- R. Johnson, RETS/REMP Specialist
- B. Kapellas, Operations Director
- D. Ketchledge, Engineering
- J. Knight, Director, Site Engineering
- M. Knott, Instrument Maintenance Manager
- S. Kvasnicka, NDE Level III
- D. Leggett, Chemistry Manager
- G. Lupia, Corporate Buried Pipe Engineer
- P. Mankoo, Chemistry Supervisor
- G. Morrow, Shift Operations Superintendent
- M. McDonald, Maintenance Director
- T. Mohr, Engineering Program Manager
- P. OBrien, Regulatory Assurance - NRC Coordinator
- D. OFlanagan, Security Manager
- M. Otten, Operations Training Manager
- B. Painter, ALARA Manager
- R. Ruffin, Licensing Engineer
- D. Schiavoni, Engineering
- J. Sipek, Work Control Director
Attachment
- R. Stachniak, Engineering
- R. Sisk, Buried Pipe Program Owner
- L. Torres, Engineering
- R. Urbaneck, Cathodic Protection Program Owner
Attachment
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None.
Closed
Temporary Instruction TI Review of the Industry Initiative to Control Degradation of 2515/182, Phase II Underground Piping and Tanks Attachment