IR 05000263/2003006
| ML040230462 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 01/22/2004 |
| From: | Burgess B NRC/RGN-III/DRP/RPB2 |
| To: | Thomas J. Palmisano Nuclear Management Co |
| References | |
| IR-03-006 | |
| Download: ML040230462 (39) | |
Text
January 22, 2004
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT NRC INTEGRATED INSPECTION REPORT 05000263/2003006
Dear Mr. Palmisano:
On December 31, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Monticello Nuclear Generating Plant. The enclosed integrated inspection report documents the inspection findings, which were discussed on January 15, 2004, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based upon the results of this inspection no findings of significance were identified.
In accordance with 10 CFR 2.790 of the NRC's "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) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Docket No. 50-263 License No. DPR-22
Enclosure:
Inspection Report 05000263/2003006 w/Attachment: Supplemental Information See Attached Distribution
DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML040230462.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII NAME BBurgess:ags DATE 01/22/04 OFFICIAL RECORD COPY
REGION III==
Docket No:
50-263 License No:
DPR-22 Report No:
05000263/2003006 Licensee:
Nuclear Management Company, LLC Facility:
Monticello Nuclear Generating Plant Location:
2807 West Highway 75 Monticello, MN 55362 Dates:
October 1 through December 31, 2003 Inspectors:
S. Burton, Senior Resident Inspector R. Orlikowski, Resident Inspector C. Brown, Clinton Resident Inspector S. Ray, Braidwood Senior Resident Inspector M. Jordan, Reactor Engineer D. Nelson, Radiation Specialist R. Gibbs, Senior Risk Analyst T. Ploski, Senior Emergency Preparedness Analyst Observers:
None Approved by:
B. L. Burgess, Chief Branch 2 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000263/2003006; 10/01/2003 - 12/31/2003; Monticello Nuclear Generating Plant,Routine integrated Inspection Report.
This report covers a 3-month period of baseline resident inspection and announced baseline inspections of radiation protection. The inspections were conducted by Region III reactor inspectors, a regional radiation specialist inspector, a regional emergency preparedness inspector, and the resident inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A.
Inspector-Identified and Self-Revealed Findings No findings of significance were identified.
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Monticello operated at full power for the entire assessment period except for brief down-power maneuvers to accomplish rod pattern adjustments and to conduct planned surveillance testing activities.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, and Emergency Preparedness
1R01 Adverse Weather
a. Inspection Scope
The inspectors performed a detailed review of the licensees procedures and a walkdown of two systems to observe the licensees preparations for adverse weather, including conditions that could result from freezing temperatures. The inspectors focused on plant specific design features for the systems and implementation of the procedures for responding to or mitigating the effects of adverse weather. Inspection activities included, but were not limited to, a review of the licensees adverse weather procedures, preparations for the winter season, and a review of analysis and requirements identified in the Updated Safety Analysis Report (USAR). The inspectors also verified that actions specified by plant specific procedures were appropriate. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors evaluated readiness for seasonal susceptibilities for the following systems for a total of two samples:
- condensate storage tanks, during the week ending November 22, 2003; and
- intake structure, during the week ending November 22, 2003.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial System Walkdown
a. Inspection Scope
The inspectors performed partial walkdowns of accessible portions of trains of risk-significant mitigating systems equipment. The inspectors reviewed equipment alignment to identify any discrepancies that could impact the function of the system and potentially increase risk. Identified equipment alignment problems were verified by the inspectors to be properly resolved. The inspectors selected redundant or backup systems for inspection during times when equipment was of increased importance due to unavailability of the redundant train or other related equipment. Inspection activities included, but were not limited to, a review of the licensees procedures, verification of equipment alignment, and an observation of material condition, including operating parameters of equipment in-service. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following equipment trains to verify operability and proper equipment line-up for a total of three samples:
- Division 1 residual heat removal (RHR) system walkdown with Division 2 RHR system out-of-service for maintenance, during the week ending November 8, 2003;
- reactor core isolation cooling (RCIC) system, during the week ending November 22, 2003; and
- 11 emergency diesel generator emergency service water (EDG ESW) with 12 EDG ESW out-of-service for maintenance, during the week ending December 6, 2003.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors performed a complete walkdown of mitigating systems equipment. The Inspectors walked down the system to verify mechanical and electrical equipment line-ups, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspection activities included, but were not limited to, a review of past and outstanding work orders (WOs) to verify that any deficiencies did not significantly affect the system function. In addition, the inspectors reviewed the corrective action database to verify that any system equipment alignment problems were being identified and appropriately resolved.
As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following system to verify operability and proper equipment line-up for a total of one sample:
- high pressure coolant injection system (HPCI), for the weeks ending November 8, 2003 and November 15, 2003.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
The inspectors walked down risk significant fire areas to assess fire protection requirements. The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features. 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 (IPEEE), the potential to impact equipment which could initiate or mitigate a plant transient, or the impact on the plants ability to respond to a security event. The inspection activities included, but were not limited to, the control of transient combustibles and ignition sources, fire detection equipment, manual suppression capabilities, passive suppression capabilities, automatic suppression capabilities, compensatory measures, and barriers to fire propagation. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following areas for review for a total of one sample:
- Fire Zone 15-A, No. 12 DG room, during the week ending October 4, 2003.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors performed an annual review of flood protection barriers and procedures for coping with internal and external flooding. The inspection focused on verifying that flood mitigation plans and equipment were consistent with design requirements and risk analysis assumptions. The inspection activities included, but were not limited to, a review and/or walkdown to assess design measures, seals, drain systems, contingency equipment condition and availability of temporary equipment and barriers, performance and surveillance tests, procedural adequacy, and compensatory measures. The inspectors utilized the documents listed in Attachment 1 to accomplish the objectives of the inspection procedure.
The inspectors selected the following equipment for a total of two samples:
- RHR system A and B pump rooms, during the week ending November 22, 2003; and
- condensate storage tanks, during the week ending November 22, 2003.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors performed an annual review of the licensees testing of both EDG and both RHR heat exchangers. The inspection focused on potential deficiencies that could mask the licensees ability to detect degraded performance, identification of any common cause issues that had the potential to increase risk, and ensuring that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspection activities included, but were not limited to, a review of 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 criteria. The inspectors utilized the documents listed in Attachment 1 to accomplish the objectives of the inspection procedure.
The inspectors selected the following equipment for a total of two samples:
- EDG heat exchanger, for the week ending October 10, 2003; and
- RHR A and B heat exchangers, for the week ending October 10, 2003.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
The inspectors performed a quarterly review of licensed operator requalification training.
The inspection assessed the licensees effectiveness in evaluating the requalification program, ensuring that licensed individuals operate the facility safely and within the conditions of their license, and evaluated licensed operator mastery of high-risk operator actions. The inspection activities included, but were not limited to, a review of high risk activities, emergency plan performance, incorporation of lessons learned, clarity and formality of communications, task prioritization, timeliness of actions, alarm response actions, control board operations, procedural adequacy and implementation, supervisory oversight, group dynamics, interpretations of technical specifications, simulator fidelity, and licensee critique of performance. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed the following requalification activity for a total of one sample:
- a training crew during an evaluated simulator scenario that included a loss of all high pressure injection with a recirculation line break inside the drywell, which resulted in entry into several emergency operating procedures for reduced reactor level, emergency reactor pressure vessel depressurization, and drywell and torus spray initiation, during the week ending December 6, 2003.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
.1 Routine Maintenance Effectiveness Inspection
a. Inspection Scope
The inspectors reviewed systems to assess maintenance effectiveness, including maintenance rule activities, work practices, and common cause issues. Inspection activities included, but were not limited to, the licensee's categorization of specific issues including evaluation of performance criteria, appropriate work practices, identification of common cause errors, extent of condition, and trending of key parameters. Additionally, the inspectors reviewed implementation of the Maintenance Rule (10 CFR 50.65)requirements, including a review of scoping, goal-setting, performance monitoring, short-term and long-term corrective actions, functional failure determinations associated with reviewed condition reports, and current equipment performance status. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors performed the following maintenance effectiveness reviews for a total of two samples:
an issue/problem-oriented review of the stator water cooling system because it was designated as risk significant under the Maintenance Rule and the system experienced a repeat failure of the cooling water pump, during the weeks ending October 11, 2003, through November 1, 2003; and
an issue/problem-oriented review of the motor-operated valves in the RHR and other systems where valves were installed that were designated as risk significant under the Maintenance Rule, because a valve in the RHR system failed due to improper torque switch settings, during the weeks ending November 8, 2003, and November 15, 2003.
b. Findings
No findings of significance were identified.
.2 Biennial Periodic Evaluation of Maintenance Effectiveness
a. Inspection Scope
The inspectors examined the periodic evaluation report completed for the time period of December 8, 2003 through December 12, 2003. To evaluate the effectiveness of 10 CFR 50.65(a)(1) and 10 CFR 50.65(a)(2) activities, the inspectors examined a number of Monticello (a)(1) Action Plans, Functional Failures, and Condition Reports.
These same documents were reviewed to verify that the threshold for identification of problems was at an appropriate level and the associated corrective actions were appropriate. Also, the maintenance rule program documents were reviewed.
The inspectors verified that the periodic evaluation was completed within the time restraints defined in 10 CFR 50.65 (once per refueling cycle, not to exceed two years).
The inspectors also ensured that the licensee reviewed its goals, monitored structures, systems, and components performance, reviewed industry operating experience, and made appropriate adjustments to the maintenance rule program as a result of the above activities. In addition, the inspectors reviewed maintenance rule self-assessments that addressed the maintenance rule program implementation.
The inspectors also verified the following items:
the licensee properly balanced reliability and unavailability during the previous refueling cycle, including a review of safety significant structures, systems and components (SSCs).
(a)(1) goals were met, corrective action was appropriate to correct the defective condition, including the use of industry operating experience, and that (a)(1)activities and related goals were adjusted as needed.
that the licensee had established (a)(2) performance criteria, examined any SSCs that failed to meet their performance criteria, and reviewed any SSCs that had suffered repeated maintenance preventable functional failures, including a verification that failed SSCs were considered for (a)(1).
that the licensee had established (a)(2) performance criteria, examined any SSCs that failed to meet their performance criteria, and reviewed any SSCs that had suffered repeated maintenance preventable functional failures, including a verification that failed SSCs were considered for (a)(1).
The inspectors focused the inspection on the following systems for a total of four samples:
RHR system;
RHR service water system (RHRSW);
RCIC system; and
HPCI system.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed maintenance activities to review risk assessments (RAs) and emergent work control. The inspectors verified the performance and adequacy of RAs, management of resultant risk, entry into the appropriate licensee-established risk bands, and the effective planning and control of emergent work activities. The inspection activities included, but were not limited to, a verification that licensee RA procedures were followed and performed appropriately for routine and emergent maintenance, that the RAs for the scope of work performed were accurate and complete, that necessary actions were taken to minimize the probability of initiating events, and that activities to ensure that the functionality of mitigating systems and barriers were performed.
Reviews also assessed the licensees evaluation of plant risk, risk management, scheduling, configuration control, and coordination with other scheduled risk significant work for these activities. Additionally, the assessment included an evaluation of external factors, the licensees control of work activities, and appropriate consideration of baseline and cumulative risk. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed maintenance or planning for the following activities or risk significant systems undergoing scheduled or emergent maintenance for a total of two samples:
- replacement of the No. 11 stator water cooling pump, during the weeks ending October 25, 2003, and November 1, 2003; and
- routine schedule maintenance for RHR system, during the week ending November 8, 2003.
b. Findings
No findings of significance were identified.
1R14 Personnel Performance During Non-Routine Plant Evolutions and Events
a. Inspection Scope
The inspectors reviewed personnel performance to planned and unplanned non-routine evolutions to review operator performance and the potential for operator contribution to the evolution or transient. The inspectors observed or reviewed records of operator performance during the evolution. Reviews included, but were not limited to, operator logs, pre-job briefings, instrument recorder data, and procedures. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed the following for a total of two samples:
- planned single rod scram testing for work performed on a hydraulic control unit, during the weeks ending October 25, 2003, and November 1, 2003; and
- response to an unplanned trip of instrument air compressor No. 11, during the week ending December 13, 2003.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors performed operability evaluations of degraded or non-conforming systems that potentially impacted mitigating systems or barrier integrity. The inspectors reviewed operability evaluations affecting mitigating systems or barrier integrity to ensure that operability was properly justified and that the component or system remained available. The inspection activities included, but were not limited to, a review of the technical adequacy of the operability evaluations to determine the impact on technical specifications (TS), the significance of the evaluations to ensure that adequate justifications were documented, and that risk was appropriately assessed. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors reviewed the following operability evaluations for a total of one sample:
- torus return valve from the RHR system fails to establish required flow during routine surveillance, during the week ending December 13, 2003.
b. Findings
No findings of significance were identified.
1R16 Operator Workarounds (OWAs)
.1 Semiannual Review of Cumulative Effects of Operator Workarounds
a. Inspection Scope
The inspectors performed a semiannual review of the cumulative effects of OWAs for a total of one sample. The inspectors reviewed OWAs to identify any potential effect on the functionality of mitigating systems. The inspection activities included, but were not limited to, a review of the cumulative effects of the OWAs on the 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. Additionally, reviews were conducted to determine if the workarounds could increase the possibility of an initiating event, if the workarounds were contrary to training, required a change from long standing operational practices, created the potential for inappropriate compensatory actions, impaired access to equipment, or required equipment uses for which the equipment was not designed. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
b. Findings
No findings of significance were identified.
.2 Routine Review of Operator Workarounds
a. Inspection Scope
The inspectors reviewed OWAs and focused on verification of the selected workarounds impact on the functionality of a mitigating system. The inspection activities included, but were not limited to, a review of the selected workarounds to determine if the functional capability of the system or human reliability in responding to an initiating event was affected, including a review of the impact of the workarounds on the operators ability to execute emergency operating procedures. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors reviewed the following OWAs for a total of two samples:
- Operator Challenge 03-037; inconsistency between AN2 manifold pressure isolation setpoint and bottle change criteria, during the week ending October 24, 2003; and
- Operator Challenge 03-048; evaluation of torus cooling line downstream from MO-2008 for pipe thinning did not include system mission time, during the week ending October 24, 2003.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors verified that the post-maintenance test procedures and activities were adequate to ensure system operability and functional capability. Activities were selected based upon the structure, system, or component's ability to impact risk. The inspection activities included, but were not limited to, witnessing or reviewing the integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use and compliance, control of temporary modifications or jumpers required for test performance, documentation of test data, system restoration, and evaluation of test data. Also, the inspectors verified that maintenance and post-maintenance testing activities adequately ensured that the equipment met the licensing basis, TS, and USAR design requirements. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following post-maintenance activities for review for a total of five samples:
- replaced relay 27-33 in the low pressure coolant injection (LPCI) swing bus, during the week ending October 4, 2003;
- replaced control room ventilation instrumentation, during the week ending October 11, 2003;
- replaced stator water cooling water pump, during the week ending October 25, 2003;
- replaced control rod drive accumulator, during the weeks ending October 25, 2003, and November 1, 2003; and
- replaced residual heat removal service water pump, during the week ending November 22, 2003.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed surveillance testing activities to assess operational readiness and ensure that risk-significant structures, systems, and components were capable of performing their intended safety function. Activities were selected based upon risk significance and the potential risk impact from an unidentified deficiency or performance degradation that a system, structure, or component could impose on the unit if the condition were left unresolved. The inspection activities included, but were not limited to, a review for preconditioning, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use, control of temporary modifications or jumpers required for test performance, documentation of test data, TS applicability, impact of testing relative to performance indicator reporting, and evaluation of test data. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following surveillance testing activity for review for a total of one sample:
- operations reactor side checklist weekly procedure, during the weeks ending October 11, 2003, and October 25, 2003.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed temporary modifications to assess the impact of the modification on the safety function of the associated system. The inspection activities included, but were not limited to, a review of design documents, safety screening documents, USAR, and applicable TS to determine that the temporary modification was consistent with modification documents, drawings, and procedures. The inspectors also reviewed the post-installation test results to confirm that tests were satisfactory and the actual impact of the temporary modification on the permanent system and interfacing systems were adequately verified. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following temporary modifications for review for a total of four samples:
- MET fiber splice rack damaged at training center, during the week ending October 24, 2003;
- temporarily rescale recombiner flow meters, during the week ending October 24, 2003;
- RHR service water temporary seismic restraint, during the week ending November 8, 2003; and
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspectors reviewed Revisions 21 through 24 of the Monticello Nuclear Generating Plant Emergency Plan versus Revision 20 of the Plan, as well as summary/bases of changes information submitted by the licensee, in order to determine if any of the changes identified in these revisions reduced the Plans effectiveness, pending on-site inspection of the implementation of these changes.
b. Findings
The inspectors identified one revised Emergency Action Level (EAL) that was apparently based on NUMARC/NESP-007 (NUMARC-007) EAL guidance, although the licensees standard emergency classification scheme was based on the guidance of NUREG-0654/FEMA-REP-1 (NUREG 0654). This EAL revision was implemented without prior NRC approval. The inspectors also noted that the prior version of this EAL, as found in Revisions 20 and 21of the Plan, differed from the corresponding guidance of NUREG 0654. It was uncertain whether the version of this EAL in Revisions 20 and 21 had received NRC approval prior to its implementation. The aforementioned concerns were identified as an Unresolved Item (URI) pending determination of whether any violation of NRC requirements occurred, and a determination of the significance if a violation is determined to have occurred.
Specifically, during an in-office review of the aforementioned revisions of the licensees emergency plan, it was identified that the Unusual Event EAL for an on-site fire was revised beginning in Revision 22 and through Revision 24 of the Plan. The relevant EAL guidance of NUREG 0654 was as follows: Fire within the plant lasting more than 10 minutes.
The licensees interpretation of this regulatory guidance, as found in Subsection 4.2.12 of Revisions 20 and 21 of the emergency plan, was as follows:
Fire within the plant lasting more than 10 minutes after initiation of fire fighting.
EAL 1. Shift Manager determination based on report from the Fire Brigade leader after initial use of extinguishing equipment.
The revised EAL, as found in Subsection 4.2.12 of Revisions 22 through 24 of the emergency plan, was as follows:
Fire within the plant not extinguished within 15 minutes of detection.
NOTE:
Verification of the alarm in this context means those actions taken in the Control Room to determine that the Control Room alarm is not spurious.
EAL 1. Fire in buildings or areas contiguous to any of the following areas not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm: Reactor, Turbine, Radwaste, Plant Administrative, Intake Structure, Diesel Generator, Heating Boiler, Recombiner; EFT, Condensate Storage Tanks.
Corresponding EAL guidance of NUMARC-007 was as follows:
Fire within Protected Area boundary not extinguished within 15 minutes of detection.
Example EAL 1. Fire in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm.
The technical bases of this NUMARC-007 guidance clarified that the purpose of this EAL was to address fires that may be potentially significant precursors to damage of safety systems and that this EAL guidance only applied to buildings and areas contiguous to plant vital areas or other significant buildings or areas. The NUMARC-007 bases guidance also indicated that verification of the alarm meant those actions taken in the Control Room to determine that the alarm was not spurious.
The inspectors concluded that the revised Unusual Event for an on-site fire, as found in Subsection 4.2.12 of Revisions 22 through 24 of the licensees emergency plan, was an apparent interpretation of the aforementioned NUMARC-007 guidance. In response to the inspectors questions on the revised Unusual Event for an on-site fire and two revised EALs on abnormal liquid radiological effluent, the licensee submitted additional bases of changes information on all three EALs. Although the additional information resolved the inspectors concerns on the revised liquid effluent EALs, this submittal contained no information on the bases for the licensees selection of the 10 on-site areas listed in its revised EAL for an on-site fire, or bases for not including other on-site areas in this listing.
The inspectors also noted that the licensees Unusual Event EAL for an on-site fire, as stated in Subsection 4.2.12 of Revisions 20 and 21 of the licensees emergency plan, differed from NUREG 0654's EAL guidance for an on-site fire. The inspectors did not know when this interpretation of the NUREGs guidance was initially implemented in the licensees emergency plan. The inspectors were also uncertain whether other EALs in Revisions 20 through 24 of the licensees emergency plan may have been inappropriately modified by the licensee prior to Revision 20 and subsequent to NRCs last approval of the licensees emergency plan, as documented in a Safety Evaluation Report.
Title 10 CFR 50.47 (b)(4) states, in part, that, a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee. Revision 3 of Regulatory Guide (RG) 1.101 was the publication used by NRC to document endorsement of the NUMARC-007 EAL guidance as an acceptable alternative to the EAL guidance of NUREG 0654.
However, Revision 3 of RG 1.101 also indicated that, licensees may use either NUREG 0654/FEMA REP-1 or NUMARC/NSEP-007 in developing their EAL scheme but may not use portions of both methodologies.
The apparent intermingling of NUMARC-007 guidance in the revised Unusual Event EAL for an on-site fire, as found in Revisions 22 through 24 of the Plan, and the uncertain adequacy of the interpretation of NUREG 0654 guidance in the version of this EAL in Revisions 20 and 21 of the Plan, were considered a URI pending review by Office of Nuclear Reactor Regulation (NRR) specialists. Once NRR staff determine the adequacy of both versions of this EAL, the safety significance of both versions would be determined in accordance with Inspection Manual Chapter 0609. Pending completion of these activities, the aforementioned concerns are considered a URI (URI 50-263/03-06-01).
The licensee initiated Condition Report (CR) 03013347 in response to the inspectors concerns.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
1. Plant Walkdowns and Radiation Work Permit (RWP) Reviews
a. Inspection Scope
The inspectors reviewed records to determine if airborne radioactivity areas with the potential for individual worker internal exposures of >50 millirem committed effective dose equivalent (CEDE) had been identified within the facility. Work areas having a history of, or the potential for, airborne transuranics were also evaluated to verify that the licensee had considered the potential for transuranic isotopes and provided appropriate worker protection. (This review represented one sample.)
The inspectors reviewed the adequacy of the licensees internal dose assessment process for internal exposures > 50 millirem CEDE. (This review represented one sample.)
The inspectors also reviewed the licensees physical and programmatic controls for highly activated and/or contaminated materials (non-fuel) stored within spent fuel or other storage pools. (This review represented one sample.)
b. Findings
No findings of significance were identified.
.2 Radiation Worker Performance
a. Inspection Scope
The inspectors reviewed radiological problem reports, which found that the cause of the event was due to radiation worker errors, to determine if there was an observable pattern traceable to a similar cause and to determine if this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. These problems, along with planned and taken corrective actions were discussed with the radiation protection manager. (This review represented one sample.)
b. Findings
No findings of significance were identified.
2OS2 As-Low-As-Is-Reasonably-Achievable (ALARA) Planning And Controls (71121.02)
.1 Inspection Planning
a. Inspection Scope
The inspectors reviewed plant collective exposure history, current exposure trends, ongoing and planned activities in order to assess current performance and exposure challenges. This included determining the plants current three-year rolling average for collective exposure in order to help establish resource allocations and to provide a perspective of significance for any resulting inspection finding assessment. (This review represented one sample). The inspectors determined site specific trends in collective exposures and source-term measurements. (This review represented one sample).
b. Findings
No findings of significance were identified.
.2 Problem Identification and Resolutions
a. Inspection Scope
The licensees corrective action program was reviewed to determine if repetitive deficiencies and/or significant individual deficiencies in problem identification and resolution had been addressed. (This review represented one sample.)
b. Findings
No findings of significance were identified.
.3 Source-Term Reduction and Control
a. Inspection Scope
The inspectors verified that the licensee had developed an understanding of the plant source-term, that this included knowledge of input mechanisms to reduce the source term and that the licensee had a source-term control strategy in place that included a cobalt reduction strategy and shutdown ramping and operating chemistry plan which was designed to minimize the source-term external to the core. Other methods used by the licensee to control the source term including component and system decontamination, and use of shielding were evaluated. (This represented one sample).
The licensees identification of specific sources was reviewed along with exposure reduction actions and the priorities the licensee had established for implementation of those actions. The results that had been achieved against these priorities since the last refueling cycle were reviewed. For the current assessment period, source reduction evaluations were verified along with actions taken to reduce the overall source-term compared to the previous year. (This represented one sample).
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Cornerstones: Mitigating Systems, Public Radiation Safety, and Occupational Radiation Safety.
.1 Reactor Safety Strategic Area
a. Inspection Scope
The inspectors review of performance indicators (PI) used PI guidance and definitions contained in Nuclear Energy Institute (NEI) Document 99-02, Revision 2, Regulatory Assessment Performance Indicator Guideline, to verify the accuracy of the PI data. The inspection activities included, but were not limited to, conditions and data from logs, licensee event reports, condition reports, and calculations for each PI specified. As part of the inspection, the documents listed in Appendix 1 were utilized to evaluate the accuracy of PI data.
The following PIs were reviewed for a total of two samples:
- safety system unavailability for high pressure injection system, for the period of October, 2002 through September, 2003; and
- safety system unavailability for heat removal systems, for the period of October, 2002 through September, 2003.
b. Findings
No findings of significance were identified.
.2 Radiation Safety Strategic Area
a. Inspection Scope
The inspectors review of performance indicators used PI guidance and definitions contained in (NEI) Document 99-02, Revision 2, Regulatory Assessment Performance Indicator Guideline, to verify the accuracy of the PI data. The inspection activities included, but were not limited to, conditions and data from logs, licensee event reports, condition reports, and calculations for each PI specified. As part of the inspection, the documents listed in Appendix 1 were utilized to evaluate the accuracy of PI data.
The following PIs were reviewed for a total of two samples:
- occupational exposure control effectiveness, for the period of July 1, 2002, through September 30, 2003; and
- RETS/ODCM radiological effluent occurrence, for the period of July 1, 2002, through September 30, 2003.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, Occupational
Radiation Safety, and Physical Protection
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
For inspections performed and documented in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Minor issues entered into the licensees corrective action system as a result of inspectors observations are included in the list of documents reviewed attached to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Palmisano and other members of licensee management on January 15, 2004. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
Interim exits were conducted for:
- Radiation Protection Inspection with Mr. Kevin Jepsen on October 24, 2003.
- Radiation Protection Inspection with Mr. Kevin Jepsen on December 2, 2003.
- Maintenance Effectiveness Periodic Evaluation with J. Purkis on December 12, 2003.
- Emergency Preparedness inspection with Mr. S. Blegen on December 31, 2003.
4OA7 Licensee-Identified Violations
None.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- T. Palmisano, Site Vice President
- J. Purkis, Plant Manager
- R. Baumer, Licensing
- G. Bregg, Manager, Quality Services
- K. Jepsen, Radiation Protection Manager
- D. Neve, Regulatory Affairs Manager
- E. Sopkin, Director of Engineering
- D. Nordell, Site Maintenance Rule Coordinator
- G. Holthaus, Emergency Preparedness Coordinator
Nuclear Regulatory Commission
- B. Burgess, Chief, Reactor Projects Branch 2
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000263/200306-01 URI Intermingling of NUMARC-007 guidance in the revised Unusual Event EAL for an on-site fire, as found in Revisions through 24 of the Plan, and the uncertain adequacy of the interpretation of NUREG 0654 guidance in the version of this EAL in Revisions 20 and 21 of the Plan.
Closed
Temporary Instruction (TI) 2515/154: Spent Fuel Material Control and Accounting at Nuclear Power Plants. The inspectors accomplished the subject TI to gather site specific material control and accounting (MC&A) information regarding spent nuclear fuel.
Discussed
None.