IR 05000266/2009004
| ML093070151 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/02/2009 |
| From: | Michael Kunowski NRC/RGN-II/DRP/RPB5 |
| To: | Meyer L Point Beach |
| References | |
| IR-09-004 | |
| Download: ML093070151 (42) | |
Text
ber 2, 2009
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, NRC INTEGRATED INSPECTION REPORT 05000266/2009004 AND 05000301/2009004
Dear Mr. Meyer:
On September 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed report documents the inspection results, which were discussed on October 7, 2009, 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 your personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 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 Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by John S. Jandovitz, Acting for/
Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-266; 50-301;72-005 License Nos. DPR-24; DPR-27
Enclosure:
Inspection Report 05000266/2009004; 05000301/2009004 w/Attachment: Supplemental Information
REGION III==
Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27 Report No: 05000266/2009004; 05000301/2009004 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: July 1, 2009, through September 30, 2009 Inspectors: J. Jandovitz, Senior Resident Inspector (Acting)
R. Ruiz, Senior Resident Inspector (Acting)
M. Thorpe-Kavanaugh, Resident Inspector (Acting)
D. Jones, Reactor Engineer M. Munir, Reactor Engineer W. Slawinski, Senior Health Physicist D. McNeil, Senior Operations Engineer R. Walton, Operations Engineer Approved by: Michael Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000266/2009004, 05000301/2009004; 07/01/2009 - 09/30/2009; Point Beach Nuclear
Plant, Units 1 & 2; Routine Integrated Inspection Report.
This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. No findings of significance were identified. The NRCs 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 of significance were identified.
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Unit 1 was at 100 percent power throughout the inspection period with the exception of planned power reductions during routine testing.
Unit 2 was at 100 percent power throughout the inspection period with the exception of planned power reductions during routine testing.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Summer Seasonal Readiness Preparations
a. Inspection Scope
The inspectors performed a review of the licensees preparations for summer weather for the safety-related 125-volt direct current (DC) system and the service water (SW)system.
During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions.
Additionally, the inspectors reviewed the Final Safety Analysis Report (FSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. 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 the corrective action program in accordance with station corrective action procedures.
Specific documents reviewed during this inspection are listed in the Attachment to this report.
This inspection constituted one seasonal adverse weather sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings of significance 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 1 1P11-B component cooling water pump while 1P11-A component cooling water pump was out-of-service for repair;
- Unit 2 containment spray additive system; and
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, the FSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of work activities on the system, 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 any equipment alignment related issues and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the to this report.
These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings of significance 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 zones 108,109 and 113 - Unit 2 residual heat removal (RHR) pump rooms and RHR hallway;
- fire zone 318 - cable spreading room;
- fire zone 304N - north auxiliary feedwater (AFW) pump room;
- fire zone 304S - south AFW pump room;
- fire zone 308 - G01 emergency diesel generator (EDG); and
- fire zone 309 - G02 EDG.
The inspectors reviewed the 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 in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk and their potential to impact equipment which could initiate or mitigate a plant transient.
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 that fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.
These activities constituted six quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings of significance were identified.
1R06 Flooding
.1 Underground Cable Vaults
a. Inspection Scope
The inspectors selected underground bunkers and manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors determined that the cables were not submerged, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as a sump pump, the inspectors verified the device was functional. The inspectors verified that the manholes, in which submerged cables were discovered, were promptly dewatered and the conditions entered into the licensees CAP. In addition, the inspectors verified that any nonfunctioning sump pumps were entered into the licensees CAP. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues identified in the CAP to verify the adequacy and timeliness of the corrective actions. The inspectors performed a walkdown of the following underground bunkers and manholes subject to flooding:
- Z-066A and Z-067A through C.
This inspection constituted one underground vaults sample as defined in IP 71111.06-05.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review
a. Inspection Scope
On September 29, 2009, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification examinations 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 sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
.2 Facility Operating History
Completion of Sections
.2 through .8 constituted one biennial licensed operator
requalification inspection sample as defined in IP 71111.11B.
a. Inspection Scope
The inspectors reviewed the plants operating history from September 2007 through August 2009 to identify operating experience that was expected to be addressed by the Licensed Operator Requalification Training (LORT) program. The inspectors verified that the identified operating experience had been addressed by the facility licensee in accordance with the stations approved Systems Approach to Training (SAT) program to satisfy the requirements of 10 CFR 55.59(c). The documents reviewed during this inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.3 Licensee Requalification Examinations
a. Inspection Scope
The inspectors performed an inspection of the licensees LORT test/examination program for compliance with the stations SAT program which would satisfy the requirements of 10 CFR 55.59(c)(4). The reviewed operating examination material consisted of three operating tests, each containing two dynamic simulator scenarios, and five or six Job Performance Measures. The written examinations reviewed consisted of six Part B, Administrative Controls/Procedure Limits. Each examination contained approximately 30 questions. The inspectors reviewed the annual requalification operating test and biennial written examination material to evaluate general quality, construction, and difficulty level. The inspectors assessed the level of examination material duplication from week-to-week during the current year operating test. The examiners assessed the amount of written examination material duplication from week-to-week for the written examination administered in Calendar Year 2008. The inspectors reviewed the methodology for developing the examinations, including the LORT program 2-year sample plan, probabilistic risk assessment insights, previously identified operator performance deficiencies, and plant modifications. The documents reviewed during this inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.4 Licensee Administration of Requalification Examinations
a. Inspection Scope
The inspectors observed the administration of a requalification operating test to assess the licensees effectiveness in conducting the test to ensure compliance with 10 CRF 55.59(c)(4). The inspectors evaluated the performance of one operating crew in parallel with the facility evaluators during two dynamic simulator scenarios and evaluated various licensed crew members concurrently with facility evaluators during the administration of several Job Performance Measures. The inspectors assessed the facility evaluators ability to determine adequate crew and individual performance using objective, measurable standards. The inspectors observed the training staff personnel administer the operating test, including conducting pre-examination briefings, evaluations of operator performance, and individual and crew evaluations upon completion of the operating test. The inspectors evaluated the ability of the simulator to support the examinations.
b. Findings
No findings of significance were identified.
.5 Examination Security
a. Inspection Scope
The inspectors observed and reviewed the licensees overall licensed operator requalification examination security program related to examination physical security (e.g., access restrictions and simulator considerations) and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests.
The inspectors also reviewed the facility licensees examination security procedure and the implementation of security and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition) throughout the examination process. The documents reviewed during this inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.6 Licensee Training Feedback System
a. Inspection Scope
The inspectors assessed the methods and effectiveness of the licensees processes for revising and maintaining its LORT Program up-to-date, including the use of feedback from plant events and industry experience information. The inspectors reviewed the licensees quality assurance oversight activities, including licensee training department self-assessment reports. The inspectors evaluated the licensees ability to assess the effectiveness of its LORT program and their ability to implement appropriate corrective actions. This evaluation was performed to verify compliance with 10 CFR 55.59(c) and the licensees SAT program. The documents reviewed during this inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.7 Licensee Remedial Training Program
a. Inspection Scope
The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the previous biennial requalification examinations and the training from the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans.
This evaluation was performed in accordance with 10 CFR 55.59(c) and with respect to the licensees SAT program. The documents reviewed during this inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.8 Conformance With Operator License Conditions
a. Inspection Scope
The inspectors reviewed the facility and individual operator licensees' conformance with the requirements of 10 CFR Part 55. The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators and which control room positions were granted watch-standing credit for maintaining active operator licenses.
The inspectors reviewed the facility licensee's LORT program to assess compliance with the requalification program requirements as described by 10 CFR 55.59(c). Additionally, medical records for 12 licensed operators were reviewed for compliance with 10 CFR 55.53(I). The documents reviewed during this inspection are listed in the to this report.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the safety-related 480-volt alternating current (AC) breakers, following the failure-to-start of the P-32C SW pump in August 2009.
The inspectors reviewed events such as where ineffective equipment maintenance had 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/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 one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.
b. Findings
No findings of significance 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 during the weeks of:
- July 6;
- July 20;
- July 27;
- August 10; and
- August 17.
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.
These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues documented in action requests (AR):
- AR 01154121 - identified potential non-conservative TS;
- AR 01153596 - tank T-175A fuel oil results do not meet acceptance criteria;
- AR 01129591 - dampers for primary auxiliary building battery room ventilation;
- AR 01117935 - SW system unable to support battery room ventilation under worst case conditions;
- AR 01153416 - lugs came off of cable for 125-volt DC battery D-105; and
- AR 01156605 - design issue with turbine-driven AFW loss-of-voltage start instrumentation.
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 FSAR 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 also 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 six samples as defined in IP 71111.15-05.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance test activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- G-04 EDG maintenance in accordance with system operating procedure SOP-G04-001;
- Unit 2 valve 2SI-851B bolt removal & inspection;
- Unit 1 1P-11A component cooling water pump oil bubbler installation and oil change;
- D-305 125-volt DC swing battery installation; and
- P-32E SW pump rebuild.
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 TS, the FSAR, 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 of significance 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:
- 1ICP-02.003B - Unit 1 monthly reactor protection system logic test;
- TS 84 - G-04 EDG monthly test;
- TS-ECCS-002 - Unit 2 emergency core cooling system monthly venting;
- IT 08A - cold start of Unit 1 turbine-driven AFW pump and valve quarterly test (inservice testing); and
- IT 60 - Unit 1 containment isolation valves quarterly test (containment isolation valve).
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- were acceptance criteria 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;
- calibration frequencies were in accordance with TSs, procedures, the FSAR, and other applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy, and 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, and 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 American Society of Mechanical Engineers (ASME) 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 three routine surveillance testing samples, one inservice testing sample, and one containment isolation valve sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed a drill evolution on July 28, 2009, which required simulated emergency plan implementation by a licensee operations crew and response organizations. These evolutions were included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities. The inspectors also reviewed 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 CAP. Documents reviewed are listed in the to this report.
This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.
b. Findings
No findings of significance were identified.
.2 Training Observation and Emergency Preparedness Drill Observation
This section does not constitute any new additional inspection samples for this inspection procedure in the third quarter, but rather serves as clarification for inspection sample tracking purposes in the second quarter 2009 integrated inspection report.
In the second quarter 2009 integrated inspection report 05000266/2009003 and 05000301/2009003, Section 1EP6.1, the completion of an emergency preparedness drill observation inspection sample on May 6, 2009, and a drill training observation inspection sample on June 25, 2009, were not clearly delineated for inspection sample tracking purposes.
1EP7 Force-on-Force Exercise Evaluation
.1 Force-on-Force Exercise Evaluation
a. Inspection Scope
The inspectors observed licensee performance during the site emergency preparedness drill in the simulated control room. This drill was in conjunction with a Force-on-Force inspection scheduled and observed by the NRCs Office of Nuclear Security and Incident Response and documented in Inspection Report 05000266/2009201; 05000301/20090201. The inspectors observed communications, event classification, and event notification activities by the simulated shift manager. The inspectors reviewed any emergency preparedness-related corrective actions from the previous Force-on-Force exercise to determine whether they had been completed and adequately addressed the cause of the previously-identified weakness. The inspectors also observed portions of the post-drill critique to determine whether their observations were also identified by the licensees evaluators. The inspectors verified that minor issues identified during this inspection were entered into the licensees corrective action program.
This force-on-force exercise inspection constituted one sample as defined in IP 71114.07-05.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2PS2 Radioactive Material Processing and Transportation (71122.02)
.1 Radioactive Waste System
a. Inspection Scope
The inspectors reviewed the liquid and solid radioactive waste system description in the Point Beach FSAR for information on the types and amounts of radioactive waste (radwaste) generated and disposed. The inspectors reviewed the scope of the licensees audit program with regard to radioactive material processing and transportation programs to verify that it met the requirements of 10 CFR 20.1101(c).
This inspection constituted one sample as defined in IP 71122.02-5.
b. Findings
No findings of significance were identified.
.2 Radioactive Waste System Walk-downs
a. Inspection Scope
The inspectors performed walkdowns of the liquid and solid radwaste processing systems to verify that the systems agreed with the descriptions in the FSAR and the Process Control Program and to assess the material condition and operability of the systems. The inspectors reviewed the status of radwaste processing equipment that was not operational and/or was abandoned which included two boric acid evaporators, a radwaste evaporator and a cement solidification system. The inspectors reviewed the licensees evaluation of this equipment as provided in its Abandoned Equipment procedure including the administrative and physical controls in-place to ensure that the equipment would not contribute to an unmonitored release path or be a source of unnecessary personnel exposure.
The inspectors walked-down the Mausoleum Storage Building and the radiologically controlled area (RCA) outdoor yard where radioactive waste was stored to assess material condition and inventory control. The inspectors also reviewed the Safety Evaluation Report for the mausoleum facility to determine whether the facility was being utilized consistent with its design basis.
The inspectors reviewed changes to the waste processing system to verify that the changes were reviewed and documented in accordance with 10 CFR 50.59 and to assess the impact of the changes on radiation dose to members of the public, as applicable. The inspectors reviewed the current processes for transferring waste resin into shipping containers to determine if appropriate waste stream mixing and/or sampling procedures were utilized. The inspectors also reviewed the licensees methods for waste concentration averaging to determine if representative samples of the waste product were provided for the purposes of waste classification, as required by 10 CFR 61.55.
This inspection constituted one sample as defined in IP 71122.02-5.
b. Findings
No findings of significance were identified.
.3 Waste Characterization and Classification
a. Inspection Scope
The inspectors reviewed the licensees radiochemical sample analysis results for each of the licensees waste streams, including dry active waste, spent resins, blowdown evaporator bottoms and filters. The inspectors also reviewed the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). The inspectors reviewed the last two radiochemical sample analysis results (i.e., 10 CFR Part 61 analyses) including vendor laboratory data for each of the licensees waste streams, and reviewed the associated calculations to account for difficult-to-measure radionuclides. The reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization and classification program to determine if reactor coolant chemistry data was periodically evaluated to account for changing operational parameters that could affect waste stream classification and thus validate the continued use of existing scaling factors between sample analysis updates.
This inspection constituted one sample as defined in IP 71122.02-5.
b. Findings
No findings of significance were identified.
.4 Shipment Preparation and Shipment Manifests
a. Inspection Scope
The inspectors reviewed the documentation of shipment packaging, radiation surveys, package labeling and marking, vehicle inspections and placarding, emergency instructions, determination of waste classification/isotopic identification, and licensee verification of shipment readiness for seven non-excepted material and radwaste shipments made in 2008 and 2009. The shipment documentation reviewed consisted of:
- Two Low Specific Activity (LSA) Resin Shipments to Waste Processors;
- High Activity Resin (Type B(U) Package) Shipment to Waste Processor;
- LSA-II Filter Shipment to Low-Level Waste Burial Site;
- LSA-II Evaporator Bottoms Shipment to Waste Processor;
- LSA-II Contaminated Equipment Shipment to Vendor; and
- LSA-II Dry Active Waste Shipment to Waste Processor.
For each shipment, the inspectors determined if the requirements of 10 CFR Parts 20 and 61 and those of the Department of Transportation (DOT) in 49 CFR Parts 170-189 were met. Specifically, records were reviewed and staff members involved in shipment activities were interviewed to determine if packages were labeled and marked properly, if package and transport vehicle surveys were performed with appropriate instrumentation, if radiation survey results satisfied DOT requirements, and if the quantity and type of radionuclides in each shipment were determined accurately. The inspectors also determined whether shipment manifests were completed in accordance with DOT and NRC requirements, if they included the required emergency response information, if the recipient was authorized to receive the shipment, and if shipments were tracked as required by 10 CFR Part 20, Appendix G.
This inspection constituted one sample as defined in IP 71122.02-5.
Selected staff involved in shipment activities were interviewed and observed by the inspectors while performing an incoming shipment survey to determine if they had adequate skills to accomplish shipment related tasks and to determine if the shippers were knowledgeable of the applicable regulations to satisfy package preparation requirements for public transport with respect to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, and 49 CFR Part 172 Subpart H.
Also, lesson plans for safety training and function specific training for radiation protection technicians and for selected hazardous material (hazmat) employees were reviewed for compliance with the hazardous material training requirements of 49 CFR 172.704.
This inspection constituted one sample as defined in IP 71122.02-5.
b. Findings
No findings of significance were identified.
.5 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed condition reports, audits and self-assessments that addressed radioactive waste and radioactive materials shipping program deficiencies since the last inspection to verify that the licensee had effectively implemented the corrective action program and that problems were identified, characterized, prioritized and corrected. The inspectors also verified that the licensee's self-assessment program was capable of identifying repetitive deficiencies or significant individual deficiencies in problem identification and resolution.
The inspectors reviewed corrective action reports from the radioactive material and shipping programs since the previous inspection, interviewed staff and reviewed documents to determine if the following activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk:
- Initial problem identification, characterization, and tracking;
- Disposition of operability/reportability issues;
- Evaluation of safety significance/risk and priority for resolution;
- Identification of repetitive problems;
- Identification of contributing causes;
- Identification and implementation of effective corrective actions;
- Resolution of NCVs tracked in the corrective action system; and
- Implementation/consideration of risk significant operational experience feedback.
This inspection constituted one sample as defined in IP 71122.02-5.
b. Findings
No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program And Radioactive Material Control Program (71122.03)
.1 Review of Radioactive Material Control Incident
a. Inspection Scope
The inspectors reviewed an incident that occurred on May 21, 2009, that involved a contract worker who received unnecessary radiation exposure while performing inspections of the licensees electrical transformers inside the protected area. The inspectors reviewed the radiation protection staffs apparent cause evaluation of the incident, the licensees initial dose assessment for the contract worker, and the licensees plant access training modules. Transformer areas and the licensees outdoor radioactive material storage yard were walked-down as part of the follow-up inspection effort.
The licensees program for the unrestricted release of material from the RCA was reviewed and samples credited in inspection report 05000266/2008004; 05000301/2008004; therefore, this supplemental review does not represent a sample.
b. Findings
Introduction:
The inspectors identified an Unresolved Item (URI) concerning an apparent failure to adequately control radioactive material causing a contract worker to be exposed to radioactively contaminated trash.
Discussion: On May 21, 2009, a contract worker alarmed the security gatehouse portal radiation monitors while attempting to exit the protected area following completion of transformer inspections. Investigation by the licensee disclosed that the worker picked-up trash (wadded-ball of tape) found lying near one of the transformers, placed the trash in his pants pocket and approximately 1-2 hours later after completing assigned work duties alarmed the portal monitors. The tape in the workers pocket was subsequently identified by the licensee to be radioactively contaminated, primarily with cobalt-60.
Radiation measurements of the tape using portable survey instruments identified contact gamma and beta dose rates of approximately 5 millirem/hour and 500 millirad/hour, respectively. Low levels of contamination were found on the workers clothing and left hand, and that clothing was confiscated. The worker had not entered a RCA while onsite that day and should not have come into contact with any radioactive trash.
Based on the initial assessment by the inspectors, a potential performance deficiency was identified associated with the licensees radioactive material control program. The licensees assessment of the workers radiation dose is ongoing. Moreover, the issue remains under review by the NRC to determine whether the dose to the worker should be classified as occupational dose or as dose to a member of the public as defined in 10 CFR 20.1003. The issue is categorized as an URI pending completion of the licensees dose assessment and further NRC review (URI 05000266/2009004-01; 05000301/2009004-01).
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
.1 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 performance indicator for Units 1 and 2 for the third quarter 2008 through the second quarter 2009. 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 5, were used. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection Reports for July 2008, through June 2009 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 of significance were identified.
.2 Mitigating Systems Performance Index - High Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the MSPI - High Pressure Injection Systems performance indicator Units 1 and 2 for the third quarter 2008 through the second quarter 2009. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection Reports for July 2008, through June 2009 to validate the accuracy of the submittals.
To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Revision 5, were used. 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 Attachment to this report.
This inspection constituted two MSPI high pressure injection system samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.3 Mitigating Systems Performance Index - Cooling Water Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems PI for Unit 1 and Unit 2 for fourth quarter 2008 through the second quarter 2009. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Revision 5, were used. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection Reports for October 2008, through June 2009 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 corrective action program 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 MSPI cooling water system samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.4 Reactor Coolant System (RCS) Specific Activity
a. Inspection Scope
The inspectors sampled licensee submittals for the RCS Specific Activity PI for Units 1 and 2 for the period from the third quarter 2008 through the second quarter 2009. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Revision 5, was used.
The inspectors reviewed Chemistry Department records including RCS isotopic analyses completed in July 2008 through June 2009, to determine if the greatest dose equivalent iodine values obtained during steady state operations corresponded to the values reported to the NRC. The inspectors also reviewed selected dose equivalent iodine calculations including the accuracy of thyroid dose conversion factors used in the licensees calculation. Sample collection and analyses methods, corresponding station procedures and condition reports were reviewed and discussed with chemistry staff. In addition to record reviews, the inspectors observed chemistry technicians obtain and analyze a RCS 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 of significance were identified.
4OA2 Identification and Resolution of Problems
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
.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 that 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: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that 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 listed 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 of significance 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 of significance were identified.
.3 Annual Sample: Review of Operator Workarounds (OWAs)
a. Inspection Scope
The inspectors evaluated the licensees implementation of the 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 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. 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 operator workaround annual inspection sample as defined in IP 71152-05.
b. Findings
No findings of significance were identified.
.4 Selected Issue Follow-Up Inspection: Condenser Fouling and Potential Extent of
Condition for Service Water System
a. Inspection Scope
The inspectors elected to review the licensees corrective actions associated with recent issues with the condenser fouling and potential extent of condition for the safety-related service water system.
The inspection criteria for this review included, the completeness and accuracy of the identification of the problem, the extent of condition, classification and resolution of the issue commensurate with its safety significance, the identification of the causes of the problem, identification of corrective actions and verification that the corrective actions have been implemented. Documents reviewed are listed in the Attachment to this report.
This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.
b. Findings
No findings of significance were identified.
.5 Semi-Annual Trend Review
This section does not constitute any new additional inspection samples for this inspection procedure in the third quarter, but rather serves as clarification that the inspection sample documented in the first quarter 2009 integrated inspection report did not occur for inspection sample tracking purposes. In the first quarter 2009 integrated inspection report 05000266/2009002 and 05000301/2009002, Section 4OA2.3, the completion of a semi-annual trend review inspection sample was inadvertently documented when the sample was not complete.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Apparent Violation (AV)05000266/2009008-01; 05000301/2009008-01;
Failure to Notify the NRC of a Permanent Illness or Disability of a Licensed Operator.
This event, which occurred on March 9, 2009, documented the failure of the facility to notify the NRC within 30 days of a permanent change in the health of a licensed operator. The facility was responsible to notify the NRC within 30 days of a permanent change in the health of an operator that may disqualify that operator from holding an NRC operators license. The NRC reviewed the licensees corrective actions which included:
- (1) performing an extent of condition evaluation which identified several additional licensed operators having medical conditions that required NRC notification;
- (2) a review of the NRC Operator Licensing Frequently Asked Questions webpage and NUREG-1021, Revision 9, Supplement 1;
- (3) conducting a series of information sharing sessions with licensed operators; and
- (4) performing periodic self-assessments of the operator license medical condition reporting program. It was determined that the licensee has complied with, and completed all corrective actions associated with this apparent violation. This apparent violation is closed. Documents reviewed as part of this inspection are listed in the Attachment to this report.
.2 (Closed) Apparent Violation (AV)05000266/2009008-02; 05000301/2009008-02;
Failure to Provide Complete Information to the NRC which Impacted a Licensing Decision.
This event, which occurred on March 9, 2009, documented the failure of the facility to provide complete and accurate information concerning licensed operator medical health to the NRC. It was determined that the facility licensee provided inaccurate information to the NRC when it failed to provide pertinent information concerning compensatory medical measures for certain licensed operators. The NRC reviewed the licensees corrective actions which included:
- (1) ensuring correct information is provided to the NRC;
- (2) performing an extent of condition evaluation;
- (3) reviewing the NRC Operator Licensing Frequently Asked Questions webpage and NUREG-1021, Revision 9, Supplement 1;
- (4) revising procedures associated with licensed operator recordkeeping and submittal of applications;
- (5) conducting a series of information sharing sessions with licensed operators;
- (6) revising the administrative procedure defining licensed operator application requirements; and
- (7) performing periodic self-assessments of the operator license medical condition reporting program. It was determined that the licensee has complied with, and completed all corrective actions associated with this apparent violation. This apparent violation is closed. Documents reviewed as part of this inspection are listed in the Attachment to this report.
4OA5 Other Activities
.1 Licensee Strike Contingency Plans
a. Inspection Scope
The inspectors reviewed the licensees work stoppage plans, in accordance with inspection procedure 92709 to determine if the plans adequately addressed the areas of reactor operations, emergency planning, facility security, fire protection, technical specifications, and other regulatory requirements in the event of an employee strike or management lockout. The inspectors reviewed records and conducted interviews with licensee staff to verify that qualified personnel would be available to meet the minimum requirements for safe operation of the plant, if a strike or lockout were to occur. No actual work stoppage occurred during the inspection period.
This inspection constituted one sample as defined in IP 92709.
b. Findings
No findings of significance were identified.
.2 Operation of an Independent Spent Fuel Storage Installation (ISFSI) (60855.1)
Loading Campaign
a. Inspection Scope
The inspectors observed and evaluated the licensees loading of canisters during the campaign and the transfer of storage casks to the ISFSI pad to verify compliance with the applicable Certificate of Compliance conditions and procedures. Specifically, the inspectors assessed the lifting of a transfer cask from the spent fuel pool, weld inspection activities, vacuum drying, down loading of the transfer cask, transfer of the canister to the storage cask, and transfer of the storage cask to the ISFSI pad. The inspectors reviewed daily radiation dose records for the staff that performed work to verify that the radiation doses received were at or below the licensees dose estimates.
The inspectors also verified that the contamination and radiation levels from the transfer cask and the loaded canister, as well as the storage cask, were well below the regulatory limits and the licensees administrative limits. In addition, the inspectors reviewed any condition reports and the associated follow up actions that were generated in response to cask/canister loading and transfer activities. The inspectors verified that the licensee took adequate corrective actions in a timely manner to correct issues.
This inspection constituted one sample as defined in IP 60855.1.
b. Findings
No findings of significance were identified.
.3 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 7, 2009, the inspectors presented the inspection results to Mr. L. Meyer, and other members of the licensee staff. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- Public Radiation Safety Radwaste Processing and Transportation inspection and review of radioactive material control incident with Mr. J. Bjorseth and other licensee staff following the onsite inspection effort on July 10, 2009, and with Mr. D. Craine during a teleconference on August 28, 2009; and
- The results of the licensed operator requalification training program inspection and closure of the Severity Level III Violation for licensed operator medical issues with the Site Vice President, Mr. L. Meyer, on September 4, 2009.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Amundson, Training Operations Supervisor
- J. Bjorseth, Plant Manager
- D. Craine, Radiation Protection, General Supervisor
- M. Durbin, Training Operations Supervisor
- R. Farrell, Radiation Protection Manager
- R. Flessner, Reactor Engineering and Performance
- F. Flentje, Regulatory Affairs Supervisor
- R. Freeman, Emergency Preparedness Manager
- R. Harrsch, Operations Site Director
- D. Lauterbur, Training Manager
- L. Meyer, Site Vice-President
- J. Pierce, Training Operations Supervisor
- B. Scherwinski, Licensing
- J. Schweitzer, Operations Support Manager
- G. Vickery, Work Management Manager
Nuclear Regulatory Commission
- J. Poole, Point Beach Project Manager, Office of Nuclear Reactor Regulations
- M. Kunowski, Chief, Division of Reactor Projects, Branch 5
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000266/2009004-01 URI Radioactive Material Control Incident Follow-up
- 05000301/2009004-01 (Section 2PS3)
Closed
- 05000266/2009008-01; AV Failure to Notify the NRC of a Permanent Illness or
- 05000301/2009008-01 Disability of a Licensed Operator. (Section 4OA3.1)
- 05000266/2009008-02; AV Failure to Provide Complete Information to the NRC
- 05000301/2009008-02 which Impacted a Licensing Decision. (Section 4OA3.2)
Attachment