IR 05000261/2003006
| ML040120777 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/12/2004 |
| From: | Fredrickson P NRC/RGN-II/DRP/RPB4 |
| To: | Moyer J Carolina Power & Light Co |
| References | |
| IR-03-006 | |
| Download: ML040120777 (36) | |
Text
ary 12, 2004
SUBJECT:
H.B. ROBINSON NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2003006
Dear Mr. Moyer:
On December 13, 2003, the US Nuclear Regulatory Commission (NRC) completed an inspection at your H. B. Robinson reactor facility. The enclosed integrated inspection report documents the inspection findings, which were discussed on December 12, with Mr. Chris Burton 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.
Based on the results of this inspection, the inspectors identified one issue of very low safety significance (Green). This issue was determined to involve a violation of NRC requirements.
However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this issue as a non-cited violation, in accordance with Section VI.A of the NRC Enforcement Policy. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the H.B. Robinson facility.
CP&L 2 In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) components of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Paul E. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23
Enclosure:
NRC Inspection Report 05000261/2003006 w/Attachment: Supplemental Information
REGION II==
Docket No: 50-261 License No: DPR-23 Report No: 05000261/2003006 Licensee: Carolina Power and Light Company Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: September 14 - December 13, 2003 Inspectors: R. Hagar, Senior Resident Inspector D. Jones, Resident Inspector L. Mellen, Senior Emergency Preparedness Inspector (Sections 1EP1, 1EP4 & 4OA1)
J. Kreh, Emergency Preparedness Inspector (Sections 1EP1, 1EP4 & 4OA1)
A. Nielsen, Health Physicist (Sections 2PS1 & 4OA1)
Approved by: P. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000261/2003-006; 09/14/2003 - 12/13/2003; H.B. Robinson Steam Electric Plant, Unit 2;
The report covered a three-month period of inspection by resident inspectors and announced inspections by emergency preparedness and health physicist inspectors. One Green violation was identified. The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Emergency Preparedness
- Green.
The inspectors identified a non-cited violation of 10 CFR 50.47(b)(2),
Emergency Plans, for failure to maintain, at all times, adequate on-site staffing to provide initial facility accident response in the Emergency Action Levels following a seismic event.
This finding is greater than minor because it is associated with the Emergency Preparedness Cornerstone attribute of Emergency Response Organization Readiness to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using the Emergency Preparedness SDP and was determined to be of very low safety significance because it did not result in a complete loss of any planning standard function required by 10 CFR 50.47 (b)(2). (Section 1EP4)
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status: The unit operated at full rated thermal power from the beginning of this inspection period until the morning of November 16, when power was reduced to 52 percent to enable secondary-plant maintenance work. The unit was returned to full power during the evening of November 16, and operated at full power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
a. Inspection Scope
After the licensee completed preparations for seasonal low temperature, the inspectors walked down the auxiliary feedwater system and the refueling water storage tank to verify that their safety related functions would not be affected by adverse weather. The inspectors reviewed documents listed in the Attachment, observed plant conditions, and evaluated those conditions using criteria documented in Procedure AP-008, Cold Weather Preparations.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
a. Inspection Scope
Partial System Walkdowns The inspectors performed the following three partial system walkdowns, while the indicated systems, structures, and/or components (SSCs) were out-of-service for maintenance and testing:
System Walked Down SSC Out-of-Service Date Inspected A Emergency Diesel Generator B Emergency Diesel Generator October 15 Primary Air Compressor; D Instrument Air Compressor November 17 A and B Instrument Air Compressors Residual Heat Removal, Residual Heat Removal, December 3 Train B Train A To verify the operability of the selected trains or systems under these conditions, the inspectors compared observed positions of valves, switches, and electrical power breakers to the procedures and drawings listed in the Attachment.
Complete System Walkdown The inspectors conducted a detailed review of the alignment and condition of the component cooling water system. To determine the proper system alignment, the inspectors reviewed the procedures, drawings, and FSAR sections listed in the
.
The inspectors walked down the system to verify that the existing alignment of the system was consistent with the correct alignment. Items reviewed during the walkdown included the following:
- Valves are correctly positioned and do not exhibit leakage that would impact the function(s) of any given valve.
- Electrical power is available as required.
- Major system components are correctly labeled, lubricated, and cooled or ventilated.
- Hangers and supports are correctly installed and functional.
- Essential support systems are operational.
- Ancillary equipment or debris does not interfere with system performance.
- Tagging clearances are appropriate.
- Valves are locked as required by the licensees locked valve program.
The inspectors reviewed the documents listed in the Attachment to verify that the ability of the system to perform its functions could not be affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, and other system-related issues tracked by the engineering department.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
For the six areas identified below, the inspectors reviewed the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures, to verify that those items were consistent with FSAR Section 9.5.1, Fire Protection System, and FSAR Appendix 9.5.A, Fire Hazards
Analysis.
The inspectors walked down accessible portions of each area and reviewed results from related surveillance tests, to verify that conditions in these areas were consistent with descriptions of the areas in the FSAR.
The following areas were inspected:
Fire Zone Description Diesel Generator Room - A Auxiliary Building Hallway Battery room Unit 2 Cable Spreading Room E-1 / E-2 Electrical Switchgear Room Switchyard Transformers Also, to evaluate the readiness of the licensees personnel to prevent and fight fires, the inspectors observed fire brigade performance during an announced fire drill in the turbine building. This drill simulated a fire in the A main feedwater pump. Documents reviewed are listed in the Attachment.
The inspectors also reviewed Action Request (AR) 102750, Testing of Heat Actuated Devices, to verify that the licensee identified and implemented appropriate corrective actions.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
Internal Flooding Because the 226' elevation of the reactor auxiliary building contains risk-significant SSCs which are susceptible to flooding from postulated pipe breaks, the inspectors walked down that elevation to verify that the area configuration, features, and equipment functions were consistent with the descriptions and assumptions used in FSAR Sections 3.6.2, Postulated Piping Failures in Fluid Systems Outside of Containment, and 9.5.1.4.4.4.3, Fire Suppression Water Damage Control Features. The inspectors also reviewed the operator actions credited in the analysis, to verify that the desired results could be achieved using the plant procedures listed in the Attachment.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
The inspectors observed licensed-operator performance during requalification simulator training for crew 2, to verify that actual operator performance was consistent with expected operator performance, as described in Full Scope Scenario LOCT-05-02, Revision 2. During this training, which tested the operators ability to correctly respond to an unisolable, stuck-open, power-operated relief valve on the reactor coolant system pressurizer, the inspectors focused on clarity and formality of communication, use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight.
The inspectors also observed the post-training critique to verify that the licensee identified deficiencies and discrepancies that occurred during the simulator training.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the two degraded SSC performance problems listed below to verify the licensees appropriate handling of these performance problems or condition in accordance with 10CFR50, Appendix B, Criterion XVI, Corrective Action, and 10CFR50.65, Maintenance Rule.
- Multiple functional failures of the steam generator power-operated relief valves, as described in AR 77823
- Damage to diesel generator fuel transfer pump power cables during installation, as described in AR 76171.
In their reviews, the inspectors focused on the following:
- Appropriate work practices,
- Identifying and addressing common cause failures,
- Scoping in accordance with 10 CFR 50.65(b),
- Characterizing reliability issues (performance),
- Charging unavailability (performance),
- Trending key parameters (condition monitoring),
- 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and
- Appropriateness of performance criteria for SSCs/functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified (a)(1).
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
For the five time periods listed below, the inspectors verified that the licensee performed adequate risk assessments and implemented appropriate risk management actions when required by 10CFR50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk was promptly assessed, and that appropriate risk management actions were promptly implemented. Those periods included the weeks that began on the following days:
- September 14 Including emergent work associated with signal spiking on a power range instrumentation channel (NI-42),
- October 6 Including emergent work associated with NI-42 and reactor coolant system loop 2 temperature instrumentation,
- October 20 Including emergent work associated with the failure of the dedicated shutdown diesel generator during a surveillance test,
- November 16 Including emergent work associated with replacing a seal on the C component cooling water pump, and
- November 30
b. Findings
No findings of significance were identified.
1R14 Personnel Performance During Nonroutine Plant Evolutions
a. Inspection Scope
During the non-routine evolutions identified below, the inspectors observed plant instruments and operator performance to verify that the operators performed in accordance with the associated procedures and training.
- The planned downpower from full power to 52 percent power during the morning of November 16, to enable the licensee to perform maintenance on some secondary-plant components, and
- The return to full power during the evening of November 16.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the operability determination associated with AR 110115, which described the licensees discovery of an error in the calculation that demonstrated the operability of the control room emergency filtration system. The inspectors assessed the adequacy of the evaluation, the need for any necessary compensatory measures, and compliance with the TS. The inspectors also verified that the operability determination was completed as described in Procedure PLP-102, "Operability Determinations." In addition, the inspectors compared the justifications made in the determination to the requirements from the TS and the descriptions in the FSAR to verify that operability was properly justified, and that the control room emergency filtration system remained available, such that no unrecognized increase in risk occurred.
b. Findings
No findings of significance were identified.
1R16 Operator Work-Arounds
a. Inspection Scope
The inspectors reviewed the following two operator workarounds, to verify that they did not affect either the functional capability of the related system in responding to an initiating event, or the operators ability to implement abnormal or emergency operating procedures:
Number Description 03-009 Manual operation of control room ventilation to prevent exceeding design air flow during emergency pressurization 03-010 Manual turbine control is required due to failure of automatic control
b. Findings
No findings of significance were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For each of the six post-maintenance tests listed below, the inspectors witnessed testing and/or reviewed the test data, to verify that test results adequately demonstrated restoration of the affected safety function(s) described in the FSAR and TS. The tests included the following:
Related Date Test Procedure Title Maintenance Activity Inspected OST-352-3 Comprehensive Flow Breaker and Limitorque October 1 Test for Containment grease inspection for MOV-Spray Pump A 880A (spray pump A discharge valve)
OST-252-2 Residual Heat Test the thermal overload October 21 Removal System and inspect Limitorque Valve Test - Train B operator lubrication for two motor-operated valves OST-402-1 Emergency Diesel Replace the diesel fuel oil October 29 Generator A Diesel transfer pump A motor Fuel Oil System Flow cable Test OST-201-1 Motor-Driven Calibrate the pump November 4 Auxiliary Feedwater discharge pressure System Component gauges, inspect Limitorque Test - Train A operator lubrication for a motor-operated valve MST-012 Maintenance and Replacement of November 13 Testing of Reactor undervoltage trip and shunt Trip and Bypass trip attachment Breakers (Annually)
OST-101-1 [Chemical & Volume Valve replacement on November 13 Control System] charging pump A Component Test Charging Pump A
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
For the six surveillance tests identified below, the inspectors witnessed testing and/or reviewed the test data, to verify that the SSCs involved in these tests satisfied the requirements described in the TS, the FSAR, and applicable licensee procedures, and that the tests demonstrated that the SSCs were capable of performing their intended safety functions.
Test Procedure Title Date Inspected OST-201-2 Motor-Driven Auxiliary Feedwater System September 18 Component Test - Train B OST-701-8* V12-10 and V12-11 Inservice Valve Test October 1 OST-409-2 Emergency Diesel Generator B Fast Speed October 15 Start PIC-302 Pressure and Vacuum Gauges October 20 OST-910 Dedicated Shutdown Diesel Generator October 23 (Monthly)
OST-401-2 Emergency Diesel Generator B Slow Speed November 12 Start
- This procedure included inservice testing requirements.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modification described in Engineering Change 53641, Temporary Modification for Jumpering Out Cell(s) on the [Dedicated Shutdown -
Uninterruptible Power Supply] Battery, to verify that the modification did not affect the safety functions of important safety systems, and to verify that the modification satisfied the requirements of Procedure EGR-NGGC-005, Engineering Change, and 10CFR50, Appendix B, Criterion III, Design Control.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP1 Exercise Evaluation
a. Inspection Scope
Prior to an emergency preparedness exercise conducted on October 7, the inspectors reviewed the exercise objectives and scenario, to verify that they were designed to test major elements of the licensees emergency plan. On October 7, the inspectors observed and evaluated the licensees performance during the exercise, as well as selected proceedings related to the licensees conduct of the exercise. Licensee activities inspected during the exercise included those occurring in the control room simulator, technical support center, operational support center, and emergency operations facility. The inspectors focused on the risk-significant activities of event classification, notification of governmental authorities, onsite protective actions, offsite protective action recommendations, and accident mitigation. The inspectors also evaluated command and control, the transfer of emergency responsibilities between facilities, communications, and adherence to emergency plan implementing procedures. The performance of the emergency response organization was evaluated against applicable licensee procedures and regulatory requirements. To evaluate the licensee's self-assessment process, the inspectors attended the post-exercise critique and the presentation of critique results to plant management.
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a. Inspection Scope
The inspectors reviewed changes to the Radiological Emergency Plan (REP), as contained in Revisions 53 and 54, against the requirements of 10 CFR 50.54(q), to verify that the changes did not decrease REP effectiveness. The changes were also reviewed to verify that changed EALs and emergency plans continued to meet the requirements of 10 CFR 50.47(b).
b. Findings
Introduction.
A Green non-cited violation (NCV) was identified for failure to meet 10 CFR 50.47(b)(2), which required the licensee to maintain, at all times, adequate on-site staffing to provide initial facility accident response in key functional areas.
Description.
Revision 54 of the REP implemented Engineering Change 47088, which replaced the strong-motion SMA-2 recorders with more-modern version ETNA strong-motion accelerographs (recorders). The inspectors noted that the amount of time required to retrieve and analyze the data was changed from 30 minutes to 60 minutes. This change could potentially delay the declaration of a Site Area Emergency (SAE) or an Alert resulting from seismic motion by an additional 30 minutes. The original EAL wording (in Revision 17)stated:
NOTE: There will be approximately 30 minutes delay between seismic alarm at 0.01g and results from the seismic instruments.
The revised EAL wording (in Revision 18) stated:
NOTE: Retrieval and analysis of data from seismic instruments will be approximately 60 minutes.
In both REP revisions, the data must be retrieved prior to determining any classification greater than an Notification of Unusual Event (NOUE). The wording of the EALs indicated that there would be a 30 or 60 minute delay before the determination of an Alert or SAE following a seismic event. Further investigation revealed that the delay could be significantly longer because the licensee failed to maintain adequate continual on-shift staffing to provide initial analysis of this seismic data. This could further delay the determination of an Alert or SAE by approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, thereby delaying the appropriate notification of offsite authorities by up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 30 minutes before the plan change or approximately two hours with the implemented plan change. Additionally, this delay could result in the notification of the NRC at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 30 minutes to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following the seismic event vice the required 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Although the regulations do not provide an explicit time limit for classifying emergencies, they do imply that classification should be made without delay. A 15-minute guideline was established as a reasonable amount of time to classify an event.
The original plan did not meet this timeliness goal, and the revised plan further exacerbated the inadequacy. 10 CFR 50, Appendix E, Section IV.D requires licensees to have the capability to notify offsite authorities within 15 minutes of the declaration of an emergency.
10 CFR 50.72 also requires that the licensee notify the NRC immediately after notification of the appropriate State or local agencies and not later than one hour after the time the licensee declares one of the emergency classes.
Licensees are expected to have adequate personnel available at all times to assist the shift supervisor/emergency director in implementing the licensee's emergency plan. Information Notice 85-50, Timely Declaration of an Emergency Class, Implementation of an Emergency Plan, and Emergency Notifications, states that it is the licensee's responsibility to ensure that adequate personnel, knowledgeable about plant conditions and emergency plan implementing procedures, are available on shift to assist the shift supervisor to classify an emergency and activate the emergency plan, including making appropriate notifications, without interfering with plant operation. Thus, it is expected that staff resources are readily available to focus on the evaluation of conditions against the plant's EALs. Furthermore, during periods when the Emergency Operations Facility and/or Technical Support Center are activated, the additional personnel available in these facilities allows flexibility for the designation of one or more individuals to support emergency classification.
Analysis.
The inspectors determined that the licensees failure to maintain adequate on-site staffing to provide initial facility accident response following a seismic event is a performance deficiency because the licensee is expected to meet the requirements of 10 CFR 50.47(b)(2) and maintain adequate staffing to provide initial accident response capabilities. This finding is greater than minor because it is associated with the Emergency Preparedness Cornerstone attribute of ERO Readiness to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using the Emergency Preparedness SDP and was determined to be of very low safety significance because it did not result in a complete loss of any planning standard function required by 10 CFR 50.47 (b)(2).
Enforcement.
10 CFR50.47(b)(2) states that On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified. Contrary to the above, the licensee did not maintain onsite, at all times, adequate staffing to evaluate the effects of a seismic event, as described in EAL-2. Additionally, the licensee failed to provide adequate means for the timely classification of an Alert or a SAE following a seismic event. Because the failure to maintain adequate on-site staffing for Emergency Plan implementation is of very low safety significance and has been entered into the corrective action program as NCR 112813, it is being treated as an NCV consistent with Section VI.A. of the NRC Enforcement Policy. NCV 05000261/2003006-01, Failure to Maintain Adequate On-site Staff for Emergency Plan Implementation.
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed a planned licensee emergency preparedness drill to verify licensee self-assessment of classification, notification, and protective action recommendation development in accordance with 10CFR50, Appendix E. The inspectors also attended the post-drill critique to verify that the licensee properly identified failures in classification, notification and protective action recommendation development activities.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety (PS)
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a. Inspection Scope
Effluent Processing Equipment. The inspectors reviewed and evaluated the operability, availability, and reliability of selected radioactive effluent process sampling and detection equipment used for routine and accident monitoring activities. Inspection activities consisted of direct observation of installed equipment configurations and operations, and review of calibration and performance data for the liquid and gaseous effluent process systems.
The inspectors directly observed equipment material condition and assessed selected gaseous and liquid effluent processing and monitoring components against design configuration documents and operating specifications. During walk-downs, accessible sections of the liquid waste system including waste condensate tanks, waste monitor tanks, system piping, and waste disposal system liquid effluent monitor (R-18) equipment were assessed for material condition and conformance with current system design diagrams.
Inspected components of the main gaseous effluent process and release system included the waste gas decay tanks, piping leading to the plant vent, and the plant vent radiation monitoring system (R-14) equipment and associated sample lines. The inspectors interviewed chemistry supervision regarding liquid and gaseous radwaste system configurations, system modifications, and effluent monitor operation. In addition, the inspectors compared plant vent flow rates to flow rates in the R-14 sample lines to evaluate system operation for isokinetic sampling conditions.
The inspectors reviewed applicable sections of licensee effluent monitor calibration procedures and evaluated results of calibration and/or performance surveillances for selected process monitors and high efficiency particulate airborne (HEPA) filter systems.
Reviewed data included the two most recent calibration records for the R-18 and R-14 monitors and associated flowmeter instruments; the most recent HEPA surveillance record for the plant vent flowpath; recent source check results for the R-18 and R-14 detectors; and out-of-service data for the past two years for all effluent monitors.
Installed configuration, material condition, operability, and reliability for selected effluent sampling and monitoring equipment were reviewed against details documented in the following:
- RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants, June 1974;
- ANSI-N13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities;
- ANSI-N13.10-1974, ANS Specification and Performance of On-Site Instrumentation for Continuously Monitoring Radioactivity in Effluents;
- NUREG-0737, Clarification of TMI Action Plan Requirements, 1980;
- Technical Specification (TS) Section 5;
- the Offsite Dose Calculation Manual (ODCM), Rev. 22; and
- Updated Final Safety Analysis Report (UFSAR) Chapter 11.
Procedures and records reviewed during the inspection are listed in the Attachment.
Effluent Release Processing and Quality Control Activities. The inspectors evaluated licensee performance in conducting effluent release processing and Quality Control (QC)activities, including implementation of program guidance and chemistry staff proficiency.
The inspectors directly observed sampling and release operations, examined count room equipment and daily QC activities, and reviewed effluent release procedural guidance and documentation.
The inspectors directly observed the weekly collection of airborne effluent samples from the fuel handling building basement exhaust monitor (R-20) conducted as part of continuous gaseous release surveillance tests. The collection of a liquid sample from waste condensate tank D in preparation for a batch liquid effluent release also was observed. The inspectors evaluated chemistry technician proficiency in collecting, processing, and counting the samples, as well as preparing the applicable release permits.
QC activities regarding gamma spectroscopy and liquid scintillation counting instrumentation were discussed with count room technicians and health physics supervision. The inspectors reviewed records of daily QC check and trending data for all gamma spectroscopy detectors and for both liquid scintillation detectors. The inspectors reviewed calibration records for germanium detectors 1 and 2, and both liquid scintillation detectors for the past two years and evaluated the data against procedural guidance. In addition, results of the radiochemistry cross-check program were reviewed for calendar year (CY) 2002 and third quarter 2003.
Six procedures for effluent sampling, processing, and release were evaluated for consistency with licensee actions. Permits for a liquid and a gaseous release were reviewed against procedural guidance and ODCM specifications. For the gaseous effluent release, the inspectors performed independent dose calculations for comparison with the doses reported by the licensee. Changes to the ODCM were evaluated for technical adequacy and proper documentation. The inspectors also reviewed the CY 2001 and 2002 annual effluent reports for effluent release data trends and for followup of any reported anomalous releases.
Observed task evolutions, count room activities, and offsite dose results were evaluated against details and guidance documented in the following:
- 10 CFR Part 20 and Appendix I to 10 CFR Part 50;
- ODCM;
- RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) -
Effluent Streams and the Environment, December 1977;
- RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I, October 1977;
- NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, 1987;
- TS Section 5; and
- UFSAR Chapter 12.
Procedures and records reviewed during the inspection are listed in the Attachment.
Problem Identification and Resolution. Three licensee ARs and two self-assessments associated with effluent release activities were reviewed and assessed. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with Procedure CAP-NGGC-0200, Corrective Action Program, Rev. 8.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
To verify the accuracy of the PI data, the inspectors compared the licensees basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2.
Initiating Events Cornerstone For the Unplanned Power Changes PI, the inspectors compared the reported data to recorded plant performance data to verify that the licensee had accurately identified the number of unplanned power changes greater than 20 percent that occurred during the period that included the fourth quarter of 2002 through the third quarter of 2003.
Mitigating Systems Cornerstone
- Safety System Unavailability, Residual Heat Removal
- Safety System Functional Failures For these PIs, the inspectors reviewed licensee event reports (LERS), records of inoperable equipment, and Maintenance Rule records, to verify that the licensee had adequately accounted for unavailability hours and functional failures that the subject systems had experienced during the period that included the fourth quarter of 2002 through the third quarter of 2003. The inspectors also reviewed both the number of hours those systems were required to be available and the licensees basis for identifying unavailability hours. In addition, the inspectors interviewed licensee personnel associated with the PI data collection, evaluation, and distribution.
Emergency Preparedness Cornerstone
- Emergency Response Organization (ERO) Drill/Exercise Performance
- ERO Drill Participation
- Alert and Notification System Reliability Emergency Preparedness PI values submitted from October 2002 through the second quarter of 2003 were reviewed. The inspectors assessed the accuracy of the PI for ERO drill and exercise performance through a review of a sample of drill records. The inspectors reviewed training records to assess the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. For the Alert and Notification System Reliability PI, the inspectors assessed the licensees ability to notify members of the public within the 10-mile Emergency Planning Zone.
Public Radiation Safety Cornerstone The inspectors sampled licensee submittals for the Radiological Control Effluent Release Occurrence PI for the period of November 2002 through August 2003. The inspectors reviewed data reported to the NRC, procedural guidance for reporting PI information, and three ARs documented in the Attachment. In addition, the inspectors reviewed quarterly effluent dose results and chemistry key performance indicator data for the first 2 quarters of 2003.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Annual Sample Review
a. Inspection Scope
The inspectors reviewed the ARs identified below, to verify that the licensee identified the full extent of the issues, performed appropriate evaluations, and specified and prioritized appropriate corrective actions.
- AR 89711, concerning a spurious turbine runback that was experienced on April 5, 2003
- AR 74191, concerning personnel errors associated with clearance tagging
- AR 61544, concerning the failure of the B emergency diesel generator output breaker to close on May 30, 2002.
The inspectors evaluated each report against the requirements of the licensees corrective action program, as described in Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B.
b. Observations and Findings
No findings of significance were identified.
4OA3 Event Follow-up
.1 (Closed) LER 2003001-00, Failure to Complete Technical Specification Required Action
Within the Allowed Completion Time. This LER was submitted after the licensee failed on February 24, 2003, to meet the required actions of TS 3.1.7. The licensee did not verify the position of control rod H-10 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while its analog rod position indication system was inoperable, as described in Action A.1 of TS 3.1.7. Furthermore, the licensee also failed to place the unit in operational mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the required action and associated completion time were not met, as described in Action D of the same TS. The inspectors review of the associated circumstances found that control rod H-10 did not move during this period, and that the licensee restored compliance with TS 3.1.7 immediately after discovering the noncompliance, which was within 45 minutes after the noncompliance occurred. The licensee determined the causes of the noncompliance, and identified and implemented corrective actions to address those causes. No new findings were identified in the inspectors review. This finding constitutes a violation of minor significance that is not subject to enforcement action, in accordance with Section IV of the NRC's Enforcement Policy. The licensee documented the problem in AR 85523. This LER is closed.
Documents reviewed by the inspectors are listed in the Attachment.
.2 (Closed) LER 2003002-00, Failure of Automatic Containment Isolation Ventilation Isolation
During Containment Pressure Relief. This LER was submitted after two containment pressure relief isolation valves failed to close in response to a signal for them to close during a planned and monitored gaseous release from containment, on June 5, 2003. The inspectors review of the associated circumstances found that release limits had not been exceeded as a result of these failures, and that the licensees ability to manually isolate the affected penetration had not been affected. The licensee determined that these failures had been caused by a combination of a control switch failure and an earlier modification of the containment isolation circuitry which had inadvertently made that circuitry vulnerable to such a failure. The licensee identified and implemented corrective actions to address those causes. No new findings were identified in the inspectors review. This finding constitutes a violation of minor significance that is not subject to enforcement action, in accordance with Section IV of the NRC's Enforcement Policy. The licensee documented the problem in AR 95470. This LER is closed. Documents reviewed by the inspectors are listed in the
.
4OA6 Meetings, Including Exit
On December 12, the resident inspectors presented the inspection results to Mr. Chris Burton and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- J. Adams, Supervisor, On-Line Scheduling
- M. Arnold, Superintendent, Shift Operations
- R. Bach, Supervisor, Environmental & Chemistry
- C. Baucom, Supervisor, Regulatory Support
- L. Bladel, Senior Nuclear Work Management Specialist
- W. Brand, Supervisor, Health Physics Operations
- C. Burton, Director of Site Operations
- E. Caba, Superintendent, Design Engineering
- G. Cappuccio, Lead Engineer, Systems Engineering
- G. Cheatham, Radiation Protection Superintendent
- C. Church, Engineering Manager
- B. Clark, Manager - Training
- T. Cleary, Plant General Manager
- W. Farmer, Superintendent, Systems Engineering
- S. George, Senior Engineer, Systems Engineering
- W. Grantham, Configuration Management Specialist
- R. Howell, Supervisor, Emergency Preparedness
- R. Ivey, Operations Manager
- E. Kapopoulos, Outage Management Manager
- D. Knight, Superintendent, Shift Operations
- V. Leeth, Control Operator, Nuclear
- J. Lucas, Manager, Support Services - Nuclear
- G. Ludlum, Superintendent, Operations Training
- D. McCaskill, Lead Nuclear Procedure Writer
- S. Moore, Supervisor, Electrical/I&C Maintenance
- A. Musselwhite, Lead Nuclear Operations Training Instructor
- G. Pizzuti, Senior Engineer, Technical Services
- L. Smith, Superintendent, Shift Operations
- V. Smith, Senior Nuclear Procedure Writer
- J. Stanley, Superintendent, Technical Services
- D. Stoddard, Maintenance Manager
- J. Thompson, Senior Nuclear Technical Project Management Specialist
- J. Valentino, Senior Engineer, Licensing/Regulatory Programs
NRC personnel
- P. Fredrickson, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000261/2003006-01 NCV Failure to Maintain Adequate On-site Staff for Emergency Plan Implementation. (Section 1EP4)
Closed
- 05000261/2003006-01 NCV Failure to Maintain Adequate On-site Staff for Emergency Plan Implementation. (Section 1EP4)
- 05000261/2003001-00 LER Failure to Complete Technical Specification Required Action Within the Allowed Completion Time (Section 4OA3.1)
- 05000261/2003002-00 LER Failure of Automatic Containment Isolation Ventilation Isolation During Containment Pressure Relief (Section 4OA3.2)