IR 05000302/2012005
ML13028A274 | |
Person / Time | |
---|---|
Site: | Crystal River ![]() |
Issue date: | 01/28/2013 |
From: | Shane Sandal NRC/RGN-II/DRP/RPB3 |
To: | Franke J Progress Energy Florida |
References | |
IR-12-005 | |
Download: ML13028A274 (35) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 28, 2013
SUBJECT:
CRYSTAL RIVER UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000302/2012005
Dear Mr. Franke:
On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Crystal River Unit 3. The enclosed inspection report documents the inspection results, which were discussed on January 16, 2013, 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.
No NRC-identified or self-revealing findings were identified during this inspection.
However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Crystal River Unit 3 site. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Shane Sandal, Acting Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No.: 50-302 License No.: DPR-72
Enclosure:
Inspection Report 05000302/2012005 w/ Attachment: Supplemental Information
REGION II==
Docket No.: 50-302 License No.: DPR-72 Report No.: 05000302/2012005 Licensee: Florida Power Corporation Facility: Crystal River Unit 3 Location: Crystal River, FL Dates: October 1, 2012 - December 31, 2012 Inspectors: T. Morrissey, Senior Resident Inspector N. Childs, Senior Resident Inspector J. Laughlin, Emergency Preparedness Inspector (Section 1EP4)
A. Nielsen, Senior Health Physicist (Sections 2RS1, 2RS8 and 4OA1)
R. Kellner, Health Physicist (Sections 2RS7, 2RS1 and 4OA1)
W. Pursley, Health Physicist (Sections 2RS6, 2RS1 and 4OA1)
Approved by: S. Sandal, Acting Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000302/2012005; 10/01/2012 -12/31/2012; Crystal River Unit 3; Routine Integrated
Report.
The report covered a three month period of inspection by resident inspectors, an emergency preparedness inspector, and regional health physicists. The Nuclear Regulatory Commissions (NRC) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
One violation of very low safety significance, which was identified by the licensee, has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program (CAP). The violation and the CAP tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status:
Crystal River 3 began the inspection period in No Mode with the full core off-loaded to the spent fuel pool. The unit remained in this condition for the remainder of the inspection period.
REACTOR SAFETY
(R)
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
Seasonal Susceptibility: Cold Weather Preparation
a. Inspection Scope
The inspectors evaluated the licensees readiness for mitigating cold weather to assure that vital systems and components were protected from freezing in accordance with the licensees administrative instruction AI-513, Seasonal Weather Preparations, Section 4.1, Cold Weather Preparations. The inspectors walked down portions of the areas listed below to check for any unidentified susceptibilities. Operability of heat trace circuits and set points of temperature controls were verified. Condition reports (CRs)were reviewed to verify that the licensee was identifying and correcting cold weather protection issues. This inspection activity satisfies one inspection sample for seasonal weather conditions.
- alternate AC emergency diesel generator (EGDG) -1C building
- EGDG-1A and 1B rooms
- auxiliary building sea water pump room
- auxiliary building spent fuel cooling pump area
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial Equipment Walkdowns
a. Inspection Scope
The inspectors performed walkdowns of critical portions of the selected trains to verify correct system alignment. The inspectors reviewed plant documents to determine the correct system and power alignments and the required positions of select valves and breakers. The inspectors verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact mitigating system availability. The inspectors verified the following three partial system alignments through system walkdowns. Documents used to facilitate the system walkdowns are listed in the attachment.
- Service water pumps (SWP) 1B and 1C while SWP-1A was out of service for planned maintenance
- SWP-1A and 1C while SWP-1B was out of service for planned maintenance
- EGDG-1A and 1C while EGDG-1B was out of service for planned maintenance
b. Findings
No findings were identified.
1R05 Fire Protection
Fire Area Walkdowns
a. Inspection Scope
The inspectors walked down accessible portions of the plant to assess the licensees implementation of the fire protection program. The inspectors checked that the areas were free of transient combustible material and other ignition sources. Also, fire detection and suppression capabilities, fire barriers, and compensatory measures for fire protection problems were verified. The inspectors checked fire suppression and detection equipment to determine whether conditions or deficiencies existed which could impair the function of the equipment. The inspectors selected the areas based on a review of the licensees probabilistic risk assessment. The inspectors also reviewed the licensees fire protection program to verify the requirements of Final Safety Analysis Report (FSAR) Section 9.8, Plant Fire Protection Program, were met. Documents reviewed are listed in the Attachment. The inspectors toured the following five areas important to reactor safety:
- A and B train spent fuel pool cooling
- Cable spreading room
- EGDG-1A room
- HVAC equipment fan room (164 elev control complex)
- Fire pump house
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flood Protection
a. Inspection Scope
The inspectors selected three manholes and bunkers for inspection that are subject to flooding and contain equipment important for the safe operation of the plant. The manholes and bunkers listed below were inspected to verify cables were not submerged in water, cables were intact, and cable support structures were adequate to perform their functions. Documents reviewed are listed in the attachment. This inspection activity constitutes one sample representing performance of the annual inspection of cables located in underground bunkers/manholes.
- bunker SB-1 (bridge east end discharge canal; engineered safeguards (ES) DC control power for switchyard breakers)
- bunker SB-2 (bridge east end discharge canal; ES DC control power for switchyard breakers)
- Manhole E-1 (Location: hot machine shop; Circuits: circulating water pump (CWP)power cables (480 VAC) and intake systems control/alarm circuits)
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
On October 16, 2012, the inspectors observed and assessed licensed operator crew response and actions for simulator evaluated scenario SES-55, which involved a hurricane warning, an emergency feedwater initiation and control (EFIC) instrument malfunction, an ES channel reactor coolant system (RCS) pressure instrument malfunction, and a once through steam generator (OTSG) steam rupture in the reactor building (RB). The plant degraded to a point where the crew entered an Unusual Event emergency declaration. The inspectors observed the operators use of the following procedures: operating procedure OP-450, Emergency Feedwater System; emergency operating procedure EOP-02, Vital System Status Verification; EOP-05, Excessive Heat Transfer; abnormal procedure AP-340, Invalid Engineered Safeguards Actuation; and AP-510, Rapid Power Reduction.
On November 19, 2012, the inspectors observed and assessed licensed operator crew response and actions for simulator non-evaluated extended training scenario LOS-9-005C, which involved a normal plant evolution, an OTSG tube leak and eventual rupture, a reactor coolant pump controlled bleed-off isolation valve failure, an integrated control system (ICS) failure to re-ratio feedwater flows, a main steam header pressure instrument setpoint failure, and a stuck open main steam safety valve (MSSV). The plant degraded to a point where the crew entered an Unusual Event, followed by an Alert, then a Site Area Emergency declaration. The inspectors observed the operators use of the following procedures: OP-417, Containment Operating Procedure; EOP-02; EOP-05, Excessive Heat Transfer; EOP-6, Steam Generator Tube Rupture; AP-250, Radiation Monitor Actuation; AP-510, Rapid Power Reduction; and AP-545, Plant Runback.
The operators actions were observed to verify performance in accordance with the procedures mentioned in the above paragraphs. Event classification and notifications were reviewed to verify they were made in accordance with emergency management procedure EM-202, Duties of the Emergency Coordinator. The simulator instrumentation and controls were verified to closely parallel those in the actual control room. The inspectors attended the crew critique and evaluation for SES-55 to verify the licensee had entered any adverse conditions into the corrective action program. The inspectors evaluated the following attributes related to crew performance:
- clarity and formality of communication
- ability to take timely action to safely control the unit
- prioritization, interpretation, and verification of alarms
- correct use and implementation of abnormal, emergency operating, and emergency plan implementing procedures
- control board operation and manipulation, including high-risk operator actions
- oversight and direction provided by supervision, including ability to identify and implement appropriate technical specification actions, regulatory reporting requirements, and emergency plan classification and notification
- overall crew performance and interactions
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the licensees effectiveness in performing routine maintenance activities for the nuclear services and decay heat seawater system (RW). The review included an assessment of the licensees practices associated with the identification, scope, and handling of degraded equipment conditions, as well as common cause failure evaluations and the resolution of historical equipment problems. For those systems, structures, and components within the scope of the Maintenance Rule (MR)per Title 10 of the Code of Federal Regulations (CFR) 50.65, the inspectors verified that reliability and unavailability were properly monitored and that 10 CFR 50.65 (a)(1) and (a)(2) classifications were justified in light of the reviewed degraded equipment condition.
Documents reviewed are listed in the Attachment.
In addition, the inspectors reviewed the licensees MR (a)(3) Periodic Evaluation (PE)indicated below to verify the following:
- (1) completion of the PE once per refueling cycle;
- (2) licensee review of (a)(1) goals, (a)(2) performance criteria, monitoring, and preventive maintenance activities;
- (3) effectiveness of corrective actions;
- (4) industry operating experience taken into account; and
- (5) appropriate adjustments were made by the licensee as a result of the PE.
- AR 505778, Maintenance Rule (a)(3) Periodic Assessment dated May 2012 The above inspection activities constitute completion of two samples under this inspection procedure.
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
The inspectors either witnessed or reviewed post-maintenance test procedures and test activities, as appropriate, for selected risk significant systems to verify whether:
- (1) testing was adequate for the maintenance performed;
- (2) acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
- (3) test instrumentation had current calibrations, range, and accuracy consistent with the application;
- (4) tests were performed as written with applicable prerequisites satisfied; and
- (5) equipment was returned to the status required to perform its safety function. The four post-maintenance tests reviewed are listed below:
- Operating procedure OP-408, Nuclear Services Cooling System (operation of SWP-1A) after performing planned maintenance on SWP-1A per work order (WO)1914967
- Surveillance procedure SP-334A, SFP-1A Quarterly Surveillance, after motor megger and PI per WO 1872973
- Post maintenance testing of EGDG-1B air compressor AC motor EGM-1B after motor refurbishment per WO 2155326
- SP-354C, Functional Test of the Alternate AC Diesel Generator EGDG-1C, after 3-year/6-year maintenance per WOs 1829497, 1821115, and 1857983
b. Findings
No findings were identified.
1R20 Refueling and Outage Activities
Steam Generator Replacement Refueling Outage (RFO16)
a. Inspection Scope
On September 26, 2009, the Unit was shut down for a steam generator replacement refueling outage. The previous quarters NRC inspection activities in this area were documented in NRC integrated inspection report 05000302/2012004 (ADAMS Accession No. ML12298A503). To verify the licensee was managing fatigue, the inspectors reviewed the licensees EmpCenter Work Management report for the period of November 30, 2011 through November 30, 2012 and verified that there were no deviations from 10 CFR Part 26, Fitness for Duty Programs, Subpart I, Managing Fatigue, work hour requirements. In addition, the inspectors reviewed CRs documenting fatigue assessments and self-declarations for the same period. The inspectors determined that there were no fatigue waiver requests since this aspect was last reviewed during the 2011 fourth quarter inspection period. The inspectors reviewed the circumstances associated with one fatigue self-declaration and four fatigue assessments to verify the items met 10 CFR Part 26 requirements. During this quarter, the inspectors reviewed the refueling outage activities listed below to verify the activities were properly implemented. Documents reviewed are listed in the Attachment.
- outage related risk assessment monitoring
- controls associated with reactivity management of the spent fuel pool (SFP)
- controls associated with electrical and mechanical alignments for those systems used to support spent fuel pool cooling
- implementation of equipment clearances
- foreign material exclusion controls associated with the SFP
- work controls associated with the protection of SFP cooling and support systems from maintenance activities
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors either observed or reviewed the three surveillance tests listed below to verify that Improved Technical Specifications (ITS) surveillance requirements were followed and that test acceptance criteria were properly specified. The inspectors observed the tests to verify that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria had been met. Additionally, the inspectors performed reviews to verify that equipment was properly returned to service and that proper testing was specified and conducted to ensure that the equipment could perform its intended safety function following maintenance or as part of surveillance testing.
Surveillance Tests:
- Performance test PT-466, Functional Test of the Vital Bus Redundant Transformers and Static transfer Switches (A train only)
- SP-521, Quarterly Battery Check (B-Train)
- SP-354C, Functional Test of the Alternate AC Diesel Generator EGDG-1C (Slow Start and 2-year Full Load Test)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness (EP)
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The Nuclear Security and Incident Response (NSIR) headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML12009A080, ML12152A054, ML12180A514, and ML12216A351 as listed in the
.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection. Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed and reviewed one emergency response activity to verify the licensee properly classified emergency events and made the required notifications and appropriate protective action recommendations. The inspectors assessed the licensees ability to classify emergent situations and make timely notification to State and Federal officials in accordance with 10 CFR 50.72. Emergency activities were verified to be in accordance with the Crystal River Radiological Emergency Response Plan, Section 8.0, Emergency Classification System, and 10 CFR Part 50, Appendix E. Additionally, the inspectors verified that a licensee critique was conducted in order to identify performance weaknesses and necessary improvements.
- October 31, Crystal River Unit 3 2012 radiological emergency response training drill (RERP-2012-TD03, Rev 0). The drill scenario included plant equipment failures that caused the licensee to make emergency classifications and notifications as well as activate the technical support center (TSC) and the emergency operating facility (EOF). The inspectors observed the drill activities at the Unit 3 simulator and the TSC. The inspectors attended the drill critique at the TSC to verify the licensee had adequately identified any performance weaknesses and necessary improvements.
b. Findings
No findings were identified.
RADIATION SAFETY
(RS)
Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety (PS)
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The licensee is currently in an extended shutdown and the opportunity to observe radiologically significant work was limited during the week of onsite inspection.
Therefore, inspection line items requiring the observation of significant job tasks in order to evaluate job-specific controls, radiation worker performance, and Health Physics (HP)technician proficiency could not be performed.
Hazard Assessment and Instructions to Workers: During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas, high radiation areas (HRA)s, Locked High Radiation Areas (LHRA)s, and Very High Radiation Areas (VHRA)s established within the radiologically controlled area (RCA) of the auxiliary building, reactor containment building, and radioactive waste (radwaste)processing and storage locations. The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed survey records for several plant areas including surveys for alpha emitters, airborne radioactivity, and gamma surveys with a range of dose rate gradients. The inspectors also discussed changes to plant operations that could contribute to changing radiological conditions since the last inspection. Although no radiologically significant work was being performed during the week of onsite inspection, the inspectors were able to observe pre-job briefings provided to workers entering the RCA for routine, low-risk work. The inspectors also reviewed radiation work permit (RWP) details to assess communication of radiological control requirements and current radiological conditions to workers.
Hazard Control and Work Practices: The inspectors evaluated access barrier effectiveness for selected LHRA and VHRA locations and discussed changes to procedural guidance for radiological controls with HP supervisors. The inspectors reviewed implementation of controls for the storage of irradiated material within the spent fuel pool. Radiological controls established for upcoming work (including airborne controls) were evaluated for selected areas within the reactor building. The inspectors evaluated worker responses to dose and dose rate alarms through a review of electronic dosimeter alarm logs.
Control of Radioactive Material: The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors reviewed calibration records for selected release point survey instruments and discussed equipment sensitivity, alarm setpoints, and release program guidance with licensee staff.
The inspectors compared recent 10 CFR Part 61 results for the Dry Active Waste (DAW)radioactive waste stream with radionuclides used in calibration sources to evaluate the appropriateness and accuracy of release survey instrumentation. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.
Problem Identification and Resolution: The inspectors reviewed and assessed CRs associated with radiological hazard assessment and control. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure CAP-NGGC-0200, Condition Identification and Screening Process, Revision (Rev.) 35.
The inspectors also reviewed recent self-assessment results.
Radiation protection activities were evaluated against the requirements of FSAR Chapter 11, Rev. 33; Technical Specifications (TS) Section 5.8; 10 CFR Parts 19 and 20; and approved licensee procedures. Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a. Inspection Scope
Effluent Monitoring and Radwaste Equipment: During inspector walk-downs, accessible sections of the liquid and gaseous radwaste and effluent systems were assessed for material condition and conformance with system design diagrams. The inspection included floor drain tanks, liquid waste system piping, waste gas decay tanks, monitor tanks, liquid radwaste monitors, plant stack effluent monitors, and associated airborne effluent sample lines. The inspectors interviewed licensee staff regarding radwaste equipment configuration and effluent monitor operation.
The inspectors reviewed performance records and calibration results for selected radiation monitors (RM), flow meters, and air filtration systems. For effluent monitors RMA-2 (main plant stack), RMA-1 (reactor building purge exhaust), RMA-6 (fuel handling building exhaust), RML-2 Plant Liquid Discharge Line (prior to dilution) and RML-5 (liquid waste) the inspectors walked down the monitors for material condition and alignment. The last two surveillances on the control room High Efficiency Particulate Air (HEPA)/Charcoal air treatment systems also were reviewed. The inspectors evaluated out-of-service effluent monitors and compensatory action data for the period from September 2010 to September 2012.
Installed configuration, material condition, operability, and reliability of selected effluent sampling and monitoring equipment were reviewed against details documented in the following: 10 CFR Part 20; Regulatory Guide (RG) 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants; American Nuclear Standards Institute (ANSI)-N13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities; TS Section 5; the Offsite Dose Calculation Manual (ODCM) Rev 34; and FSAR, Chapter 12, Rev 33. Procedures and records reviewed during the inspection are listed in the Attachment.
Ground Water Protection: The inspectors reviewed the current groundwater sample results. The inspectors discussed interaction between the buried piping initiative and groundwater protection program. The recently completed periodic review (every five years) of the site hydrologic characterization study, and groundwater program assessment was discussed with both Chemistry and Radiation Protection representatives. In addition, status of installation of additional groundwater monitoring wells inside the berm was discussed.
Effluent Release Processing and Quality Control Activities: The inspectors reviewed recent liquid and gaseous release permits including pre-release sampling results, effluent monitor set-points, and resultant doses to the public. The inspectors also reviewed the 2010 and 2011, Annual Radioactive Effluent Release Reports (ARERR) to evaluate reported doses to the public and to review ODCM changes. The inspectors reviewed daily Quality Control data logs and calibration records for instruments used to quantify effluent sample activity including High Purity Germanium (HPGe) detectors and liquid scintillation counters. In addition, results of the 2011 and 2012 quarterly inter-laboratory cross-check program were reviewed. The inspectors reviewed an unplanned release that occurred when a leak from a valve associated with the Station Drain Tank (SDT-1), valve SDV-70, allowed small amounts of the contents of the SDT-1 to leak into the discharge pipe that carries this tank's fluid to the site settling ponds. This event was documented in the licensees corrective action program and accounted for in the 2011 ARERR.
Observed task evolutions, count room activities, and offsite dose results were evaluated against details and guidance documented in the following: 10 CFR Part 20 and Appendix I to 10 CFR Part 50; ODCM, Rev. 34; RG 1.21; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I; and TS Section 6. Procedures and records reviewed during the inspection are listed in the Attachment.
Problem Identification and Resolution: Selected CRs associated with effluent release activities were reviewed and assessed. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve selected issues in accordance with procedure CAP-NGGC-0200, Condition Identification and Screening process, Rev. 35.
The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Documents reviewed are listed in the Attachment.
The inspectors completed one specified line-item sample as detailed in IP 71124.06.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program (REMP)
a. Inspection Scope
REMP Status and Results: The inspectors reviewed and discussed recent and proposed changes applicable to Radiological Environmental and Meteorological Monitoring program activities detailed in the current FSAR and ODCM. Environmental monitoring sample results presented in the Annual Radiological Environmental Operating Report (AREOR) documents issued for calendar year (CY) 2010 and CY 2011 were reviewed and discussed. REMP vendor laboratory cross-check program results and select procedural guidance for collection, processing and analysis of airborne particulate and iodine, broadleaf vegetation, surface water, and fruit samples were reviewed and discussed with vendor personnel. Detection level sensitivities for selected environmental media analyzed by the offsite vendor environmental laboratory were reviewed and discussed. The AREOR environmental measurement results were reviewed for consistency with licensee Annual Effluent Release Report data and evaluated for radionuclide concentration trends. Licensee actions for missed airborne monitoring samples were reviewed and discussed in detail.
Site Inspection: The inspectors observed implementation of selected REMP monitoring and sample collection activities for direct radiation, atmospheric particulates and iodine, and broadleaf vegetation samples as specified in the current ODCM and applicable procedures. The inspectors observed equipment material condition and verified operability, including verification of flow rates and total sample volume results for the weekly airborne particulate filter and iodine cartridge change-out at five atmospheric sampling stations. In addition, the inspectors discussed broadleaf vegetation, surface water, and fruit sampling for selected ODCM locations. Thermo-luminescent dosimeter material condition and placement were verified by direct verification at seven locations identified in the ODCM. Land use census results, actions for missed samples including compensatory measures and availability of replacement equipment were discussed with vendor technicians and knowledgeable licensee staff. In addition, sample pump calibration and maintenance records for the installed environmental air monitoring equipment were reviewed.
The inspectors toured the primary and backup meteorological towers and observed local data collection equipment readouts. The inspectors observed the physical condition of the tower and associated instruments and discussed equipment operability, maintenance history, and backup power supplies with responsible licensee staff. For the meteorological measurements of wind speed, wind direction, and temperature, the inspectors reviewed applicable primary and backup meteorological towers instrumentation semi-annual calibration records and evaluated meteorological measurement data recovery for CY 2010 and CY 2011.
The inspectors discussed previous leaks and spills attributed to degraded equipment and piping associated with the SDT-1, hydro demolition activities, licensee monitoring activities, planned additional sampling wells, and buried piping inspection requirements, with responsible licensee representatives. Repair activities to seal the building from groundwater intrusion and proposed changes to the licensee groundwater monitoring program based on recent investigations of groundwater intrusion into the decay heat vaults also were discussed in detail. Current status and completeness of the licensees 10 CFR 50.75(g) decommissioning files were reviewed and discussed in detail.
Procedural guidance, program implementation, quantitative analysis sensitivities, and environmental monitoring results were reviewed against 10 CFR Part 20; 10 CFR Part 50, and Appendix I to 10 CFR Part 50; TS Sections 5.6.1, Procedures, 5.6.2, Programs and Manuals, and 5.7.1, Routine Reports; ODCM, Rev. 34; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment; and the Branch Technical Position, An Acceptable Radiological Environmental Monitoring Program - 1979. Licensee procedures and activities related to meteorological monitoring were evaluated against: ODCM, Rev. 34; RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and ANSI/ANS-2.5-1984, Standard for Determining Meteorological Information at Nuclear Power Sites.
Documents reviewed are listed in the Attachment.
Problem Identification and Resolution: The inspectors reviewed selected CAP documents in the areas of environmental and meteorological monitoring. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with CAP-NGGC-0200, Condition Identification and Screening Process, Rev. 35 and CAP-NGGC-205, Condition Evaluation and Corrective Action Process, Rev. 16.
The inspectors completed all of the specified line-items detailed in IP 71124.07 (sample size of 1). Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation
a. Inspection Scope
Waste Processing and Characterization: During inspector walk-downs, accessible sections of the liquid and solid radwaste processing systems were assessed for material condition and conformance with system design diagrams. Inspected equipment included radwaste storage tanks, resin transfer piping, resin and filter packaging components, and abandoned evaporator equipment. The inspectors discussed component function, processing system changes, and radwaste program implementation with licensee staff.
The 2010 Radioactive Effluent Report and radionuclide characterizations from 2009 -
2010 for each major waste stream were reviewed and discussed with radwaste staff.
For primary resin and DAW, the inspectors evaluated analyses for hard-to-detect nuclides, reviewed the use of scaling factors, and examined quality assurance comparison results between licensee waste stream characterizations and outside laboratory data. Waste stream mixing and concentration averaging methodology for primary resin and filter waste streams was evaluated and discussed with radwaste staff.
The inspectors also reviewed the licensees procedural guidance for monitoring changes in waste stream isotopic mixtures.
Radioactive Material Storage: During walk-downs of indoor and outdoor radioactive material storage areas, the inspectors observed the physical condition and labeling of storage containers and the posting of Radioactive Material Areas. The inspectors also reviewed licensee procedural guidance for storage and monitoring of radioactive material.
Transportation: Selected shipping records were reviewed for consistency with licensee procedures and compliance with NRC and Department of Transportation (DOT)regulations. The inspectors reviewed emergency response information, DOT shipping package classification, waste classification, radiation survey results, and evaluated whether receiving licensees were authorized to accept the packages. Licensee procedures for handling shipping containers were compared to manufacturer recommendations and certificate of compliance requirements. In addition, training records for selected individuals currently qualified to ship radioactive material were reviewed. The inspectors were unable observe shipment preparation activities due to a lack of outgoing shipments during the week of inspection.
Problem Identification and Resolution: The inspectors reviewed CRs in the area of radwaste processing and shipping. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure CAP-NGGC-0200, Condition Identification and Screening Process, Rev. 35. The inspectors also reviewed recent self-assessment results.
Radwaste processing, radioactive material handling, and transportation activities were reviewed against the requirements contained in the licensees Process Control Program (PCP) , FSAR Chapter 11, Rev 33, 10 CFR Part 20, 10 CFR Part 61, 10 CFR Part 71, and 49 CFR Parts 172-178. Licensee activities were also evaluated against guidance provided in the Branch Technical Position on Waste Classification (1983) and NUREG-1608, Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Objects. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES (OA)
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
Occupational Radiation Safety Cornerstone: The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for the Occupational Radiation Safety Cornerstone from November 1, 2011, through September 30, 2012. For the assessment period, the inspectors reviewed ED alarm logs and selected CRs related to controls for exposure significant areas. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in the Attachment.
Public Radiation Safety Cornerstone: The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from October 1, 2011, through September 30, 2012. For the assessment period, the inspectors reviewed cumulative and projected doses to the public and CRs related to Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual issues.
The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in the Attachment.
The inspectors completed two of the required samples specified in IP 71151.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Daily Review
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by attending daily plant status meetings, interviewing plant operators and applicable system engineers, and accessing the licensees computerized database.
b. Findings
No findings were identified.
.2 Annual Sample Review
a. Inspection Scope
The inspectors reviewed CR 540091 which documented the identification of 28 unsatisfactory below grade conduit penetrations (either missing seals or inadequately sealed) where water in-leakage into the turbine building would be possible if a probable maximum hurricane (PMH) occurred. These penetrations were identified as a result of extent of condition review inspections related to an uncapped penetration that had been discovered in the seawater room in August 2011 and documented in CR 489111. CR 540091 was selected for review due to the conditions potential to adversely impact the allowable 7 inch flood limit in the auxiliary building. Flood levels above 7 inches in the auxiliary building would impact safety-significant equipment.
The inspectors reviewed the CR to verify that the issues had been properly identified in the licensees corrective action program; safety concerns were properly classified and prioritized for resolution; reportability evaluations were sufficiently thorough; and appropriate corrective actions were initiated. The inspectors also evaluated the CR using the requirements of the licensees CAP as delineated in corrective action procedure CAP-NGGC-0200, Condition Identification and Screening Process.
Documents reviewed are listed in the Attachment.
b. Findings and Observations
One finding, a licensee identified violation (LIV), was identified and is documented in section 4OA7 of this report. The inspectors also made several observations during review of this CR and its associated documentation.
The inspectors reviewed the reportability evaluations associated with the unsatisfactory penetrations. The inspectors questioned the adequacy of these evaluations in that they estimated that a significant level of water (approximately three to four feet) would accumulate in the turbine building during PMH conditions, but concluded that none of this flood water would pass through the set of fire doors from the turbine building to the auxiliary building. The subject fire doors are rated for 2 feet of water pressure. The reportability evaluations heavily relied upon actions taken in the licensees adverse weather procedure EM-220, Violent Weather, to sandbag the fire doors prior to hurricane conditions. The inspectors did not have confidence in the adequacy of sandbagging instructions in EM-220 or that the door could withstand three to four feet of turbine building flooding to preclude flooding in auxiliary building.
As a result of the inspectors concerns, the licensee initiated CR 563931 to re-evaluate the expected flood levels in the turbine building during PMH conditions. The inspectors reviewed the completed evaluation and noted that more reasonable external flooding conditions were used and the evaluation took credit for other actions in the adverse weather procedure such as use of dewatering pumps. The inspectors also noted that the evaluation included the estimated flooding contribution from two additional unsatisfactory penetrations which were identified in August 2012 during the licensees Fukushima flooding walkdowns and documented in CRs 556385 and 557156. The inspectors concluded that, due to the location and condition of the two penetrations, their overall flooding contribution was negligible when compared to the overall flood level due to the 29 penetrations previously identified by the licensee. The new evaluation concluded that the resulting flood level through the 29 penetrations during PMH conditions would be 1.27 feet of water in the turbine building, which is within the rating of the fire doors. The inspectors concurred with the licensees conclusion that this flood level would not adversely impact the allowable flood limit in the auxiliary building.
The inspectors verified that the licensee had performed an adequate extent of condition review to identify the unsatisfactory below grade penetrations and that appropriate actions were being taken to correct the issue. The inspectors verified that, as of the end of this inspection period, 19 of the 28 unsatisfactory penetrations had been repaired.
The remaining were scheduled for repair.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel 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 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 reviews and inspection activities.
b. Findings
No findings were identified.
.2 Steam Generator Replacement Project and Containment Wall Repair (IP 50001)
a. Inspection Scope
During this quarter, the licensee performed limited field work associated with containment wall repair. As of the end of this inspection period, major field work activities had not been approved or scheduled. The licensee monitored containment stability utilizing installed acoustic and displacement sensors. The data from the sensors was periodically reviewed by the inspectors to verify containment stability.
b. Findings
No findings were identified.
.3 Institute of Nuclear Power Operations (INPO) Maintenance and Technical Training
Accreditation Report Review The inspectors reviewed the final INPO maintenance and technical training accreditation report, dated December 26, 2012. The report did not identify any significant licensee performance issues that had not been previously addressed or reviewed by the NRC.
.4 (Discussed) Temporary Instruction 2515/187 - Inspection of Near-Term Task Force
Recommendation 2.3 Flooding Walkdowns
a. Inspection Scope
As discussed in NRC integrated inspection report 05000302/2012004 (ADAMS Accession No. ML12298A503), the inspectors accompanied the licensee on a sampling basis, during their flooding walkdowns, to verify that the licensees walkdown activities were conducted using the methodology endorsed by the NRC. These walkdowns were completed in the 3rd quarter 2012 inspection period.
During this inspection period, the inspectors reviewed evaluations of two degraded penetrations that were identified during the flooding walkdowns and documented in CRs 556385 and 557156. Additional discussion regarding these degraded penetrations is included in section 4OA2.2 of this inspection report.
b. Finding Findings or violations associated with the flooding walkdowns, if any, will be documented in the 1st quarter integrated inspection report of 2013.
.5 (Closed) Temporary Instruction 2515/188, Inspection of Near-Term Task Force
Recommendation 2.3 Seismic Walkdowns
a. Inspection Scope
As discussed in NRC integrated inspection report 05000302/2012004 (ADAMS Accession No. ML12298A503), the inspectors accompanied the licensee on a sampling basis, during their seismic walkdowns, to verify that the licensees walkdown activities were conducted using the methodology endorsed by the NRC. These walkdowns were completed in the 3rd quarter 2012 inspection period.
During the 3rd quarter 2012 inspection period, the inspectors also independently performed walkdowns of the following equipment:
- Emergency feedwater pump EFP-1 (95 elevation intermediate building)
- Makeup valve MUV-23 (95 elevation auxiliary building)
The inspectors verified, as appropriate, the seismic features listed below:
- anchorage free of bent, broken, missing or loose hardware
- anchorage free of corrosion more than mild surface oxidation
- anchorage free of visible cracks in the concrete near the anchors
- anchorage configuration consistent with plant documentation
- SSCs would not be damaged from impact by nearby equipment or structures
- overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls secure and not likely to collapse onto the equipment
- attached lines had adequate flexibility to avoid damage
- area appeared to be free of potentially adverse seismic interactions that could cause a fire or flooding in the area
- area appeared to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding)
This completes the inspection activities required by TI2515/188 and the TI is closed.
b. Finding No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On January 16, 2013, the resident inspectors presented the inspection results to Mr. J.
Franke, Site Vice President, and other members of licensee management. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
4OA7 Licensee Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements, which meets the criteria of NRC Enforcement Policy Section 2.3.2 for being dispositioned as a Non-Cited Violation:
10 CFR 50, Appendix B, Criterion III, Design Controls, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions.
These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. The licensees design basis, FSAR section 2.4.2.4e, requires that all below grade penetrations be maintained with water tight seals.
Contrary to the above, the licensee did not assure that deviations from the design basis were controlled when below grade conduit penetrations were originally installed with either no seals or inadequate seals. Specifically, between August 2011 and May 2012, the licensee identified 29 penetrations that had not been originally installed with water tight seals as required by the design basis. As a result, during PMH conditions, water in-leakage through the penetrations would have resulted in an unanalyzed flood level in the turbine building, which could potentially challenge the allowable flood limit of 7 inches in the auxiliary building. The licensee entered this issue into their CAP as CR 540091.
The licensees failure to install below grade penetrations with water tight seals as required by the design basis was a performance deficiency (PD). The PD was determined to be more than minor because the condition affected the mitigating systems cornerstone for protection against external factors (flood) in that the condition would result in an unanalyzed flood level in the turbine building during probable maximum hurricane conditions. This issue prompted the licensee to perform an evaluation to verify that the unanalyzed turbine building flood level would not adversely impact the 7 inch flood limit in the auxiliary building. The evaluation concluded that this condition would result in a flood level of 1.27 feet of water in the turbine building during PMH conditions, which is within the rating of the fire doors leading from the turbine building to the auxiliary building. Therefore, the licensee concluded that flood water was not expected to migrate into the auxiliary building and the 7 inch flood limit was not impacted.
The licensee determined that this condition most likely existed since original plant construction. The plant has been in No Mode for the majority of the previous three year period. Therefore, in order to bound the risk significance of this condition, the time period in which the plant would likely experience hurricane conditions and was in either Mode 5 (Cold Shutdown) or 6 (Refueling) was considered. This time existed from approximately November 19, 2010, through November 30, 2010. The significance of the finding was determined using Manual Chapter 0609, Significance Determination Process, Appendix G, Attachment 1, Checklist 4 (PWR Refueling Operation OR PWR Shutdown Operation), issued May 25, 2004. A review of operator logs and CRs for the previously mentioned time period revealed that there was no loss of mitigating capability of core heat removal, inventory control, power availability, containment control, or reactivity control during that time. In addition, the licensee performed an evaluation which determined that the unanalyzed flood level would not have adversely impacted the 7 inch flood limit in the auxiliary building. Therefore, the finding was determined to be of very low safety significance (Green). Additional information regarding this NCV is discussed in Section 4OA2.2 of this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- B. Akins, Superintendent, Radiation Protection
- C. Bergstrom, Supervisor, Emergency Preparedness
- P. Dixon, Manager Training
- B. Foster, Manager, Operations
- J. Franke, Vice President, Crystal River Nuclear Plant
- T. Hobbs, Plant General Manager
- J. Huegel, Manager, Maintenance
- M. Kelly, Manager Outage and Scheduling
- R. Llewellyn, Superintendent Operations Training
- D. Westcott, Supervisor, Licensing
R, Wiemann, Manager, Nuclear Oversight
- B. Wunderly, Director, Engineering
NRC personnel
- D. Rich, Chief, Reactor Projects Branch 3, Division of Reactor Projects
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
None
Discussed
- 05000302/2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns (Section 4OA4.4)
Closed
- 05000302/2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns (Section 4OA4.5)