IR 05000302/2014003
| ML14293A395 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/21/2014 |
| From: | Marc Ferdas Division of Nuclear Materials Safety I |
| To: | Hobbs T Duke Energy Florida |
| References | |
| IR 2014003 | |
| Download: ML14293A395 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 21, 2014
SUBJECT:
NRC INSPECTION REPORT NO. 05000302/2014003, DUKE ENERGY FLORIDA, INC., CRYSTAL RIVER NUCLEAR PLANT, CRYSTAL RIVER, FLORIDA
Dear Mr. Hobbs:
On September 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a quarterly inspection of activities at Crystal River Nuclear Plant Unit 3 (CR-3). On-site inspections were performed on July 14-18 and August 12-14, 2014. In-office reviews of information supplied by Duke Energy Florida, Inc. were also performed during the inspection period. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with Blair Wunderly, Plant Manager, and other members of the CR-3 staff on October 6, 2014, and are described in the enclosed report.
Based on the results of this inspection, the NRC has determined that one licensee identified Severity Level IV violation of NRC requirements occurred. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, 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: (1) the Regional Administrator, Region I; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) the NRC Senior Decommissioning Inspector, Region I.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).
No reply to this letter is required. Please contact Steve Hammann, at 610-337-5399, if you have any questions regarding this matter.
Sincerely,
/RA/
Marc S. Ferdas, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety Enclosure: Inspection Report 05000302/2014003 cc w/encl: State of Florida Distribution via ListServ
EXECUTIVE SUMMARY
Duke Energy
Crystal River Nuclear Plant NRC Inspection Report No. 05000302/2014003 An announced quarterly inspection was completed at CR-3 on September 30, 2014. On-site inspections were conducted on July 14-18, and August 12-14, 2014. In-office reviews of information supplied by Duke Energy were also performed during the inspection period. The inspection included a review of operations, management oversight, and plant support activities.
The inspection consisted of observations by the inspectors, interviews with Duke Energy personnel, a review of procedures and records, and plant walk-downs. The U.S. Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561,
Decommissioning Power Reactor Inspection Program."
Based on the results of this inspection, a licensee-identified Severity Level (SL) IV Non-Cited Violation (NCV) of 10 Code of Federal Regulations (CFR) 50.82(a)(8)(ii) was identified. 10 CFR 50.82(a)(8)(ii) states, in part, that initially, three percent (3%) of the generic amount of decommissioning funds as specified in § 50.75 may be used for decommissioning planning.
Contrary to the requirement, Duke Energy identified that it used decommissioning funds which were not directly related to decommissioning planning. Specifically, the costs for three out of approximately sixty activities which were submitted for reimbursement from the decommissioning trust fund were not directly related to decommissioning planning. Because this violation resulted in no potential safety consequences and it was entered into CR-3s corrective action program, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy.
REPORT DETAILS
1.0 Background On February 20, 2013, Duke Energy sent a letter (ADAMS Accession Number ML13056A005) to the NRC certifying the permanent cessation of activities and certifying that the fuel had been permanently removed from the reactor. This met the requirements of 10 CFR 50.82(a)(1)(i) and 50.82(a)(1)(ii). CR-3 is currently in the Post Operation Transitional Phase of decommissioning as described in IMC 2561.
2.0 Post Operation Transition Phase Performance and Status Review
a. Inspection Scope
Inspection Procedures (IPs) 36801, 60801, 62801)
An announced quarterly inspection was completed at CR-3 on September 30, 2014.
On-site inspections were conducted on July 14-18, and August 12-14, 2014. In-office reviews of information supplied by Duke Energy were also performed during the inspection period. The inspection consisted of observations by the inspectors, interviews with Duke Energy personnel, a review of procedures and records, and plant walk-downs.
The inspectors assessed management oversight of the sites transition to decommissioning status and reviewed the CR-3 organization, staffing levels, and personnel qualifications to ensure safe storage of radioactive materials were not adversely impacted. Inspectors reviewed expenditures associated with decommissioning planning to determine if regulatory requirements were being met.
The inspectors reviewed the modifications being performed to stabilize the containment building and reviewed work orders associated with the weatherization and knockout restoration to verify they were completed in accordance with site procedures. The inspectors also observed equipment configuration and material staging for the weatherization project and performed a walkdown of roof knockouts 21-A and 22-A.
The inspectors reviewed the proposed plans to replace the existing spent fuel pool (SFP) cooling system with a system using air-cooled chillers to remove the heat load from the SFP and reject it to the atmosphere. The inspectors reviewed engineering change packages, 50.59 reviews, and action requests to determine that the proposed SFP cooling system would fulfill its function as specified in the Final Safety Analysis Report (FSAR), Technical Specifications (TS), and plant procedures. Inspectors also reviewed proposed changes to the CR-3 electrical distribution system. Inspectors reviewed plant drawings and summaries of four engineering change packages to determine if the proposed electrical distribution changes, as CR-3 transitions to SAFSTOR status, were consistent with TS, the design control program, and plant procedures.
The inspectors reviewed the programs for the safe wet storage of spent fuel and the inspectors performed a walkdown of the SFP and associated plant systems to determine the material condition of systems used to support SFP cooling.
The inspectors also reviewed the system abandonment of the Post-Accident Sampling System (PASS) to assure that the procedure to remove systems from service and abandon them was followed and that the PASS valve lineup specified in the system abandonment documents was accurately reflected. Inspectors also reviewed procedures and plant programs, attended pre-job briefs, and observed preventative maintenance being performed on the MTSW-3J transformer and switchgear to verify that maintenance was being performed within the established frequencies and that the equipment was being properly maintained.
b. Observations and Findings
The inspectors noted that staffing at CR-3 continued to gradually decrease and Duke Energy has a staffing plan in place which continues to the time in which they will be in SAFSTOR status. The inspectors also noted that staffing reviews were continuously being performed by Duke Energy to ensure that adequate staffing levels were being maintained to support plant activities.
The inspectors determined the CR-3 weatherization process to seal the containment building from water intrusion was being properly implemented. All knockouts had been restored with the exception of 16-I. The final step in the containment stabilization process will be the installation of wire netting between the buttresses above the roofline to mitigate the potential of any future spalled concrete from falling.
The inspectors noted the chillers which will be used for SFP cooling have been installed and Duke Energy has begun testing the chillers prior to placing them in service. The new SFP cooling system is expected to be in service by the end of October 2014.
The inspectors verified that the programs for the safe wet storage of spent fuel were being performed within the established frequencies and that the equipment was being properly maintained. The inspectors verified that the maintenance and surveillance program for systems and components had been conducted in accordance with the TS requirements and established procedures.
Duke Energy performed an assessment to verify that only charges associated with decommissioning planning were included in the requests for reimbursement from the decommissioning trust fund as allowed by 10 CFR 50.82. From the assessment, Duke Energy determined that although they had spent less than the allowed amount of funds, three of the activities should not have been classified as being associated with decommissioning planning and were erroneously included in trust fund reimbursement requests. The incorrect charges were: 1) labor charges associated with non-planning decommissioning activities; 2) security cost for SFP protection; and 3) demolition of temporary office trailers. Duke Energy entered the assessment into their corrective action program and has implemented the following corrective actions: implemented a process for the development and review of invoices for decommissioning trust fund reimbursements; developed and implemented an accounting structure that assures appropriate segregation of charges between license termination, spent fuel management, and site restoration in accordance with the decommissioning cost estimate; made corrections on the next invoices to balance the ledger; and provided training of the changes implemented.
c. Conclusions
Based on the results of this inspection, a licensee-identified SL IV NCV of 10 CFR 50.82(a)(8)(ii) was identified. 10 CFR 50.82(a)(8)(ii) states, in part, that initially, three percent (3%) of the generic amount of decommissioning funds as specified in § 50.75 may be used for decommissioning planning. Contrary to the requirement, Duke Energy used decommissioning funds which were not directly related to decommissioning planning. Specifically, the costs for three out of approximately sixty activities which were submitted for reimbursement from the decommissioning trust fund were not directly related to decommissioning planning. This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. Because this violation resulted in no potential safety consequences and it was entered into CR-3s corrective action program (CR 691179), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000302/2014003-01; Decommissioning Trust Fund Expense Not Used For Decommissioning Planning)3.0
Exit Meeting Summary
On October 6, 2014, the inspectors presented the inspection results, via teleconference, to Blair Wunderly, Plant Manager, and other members of Duke Energys staff. The inspectors confirmed that proprietary information was not removed from the site.
PARTIAL LIST OF PERSONS CONTACTED Licensee K. Ankrum, Manager Nuclear Station Finance R. Biddleman, Superintendent, Nuclear Oversight D. Demontfort, Scheduling Manager P. Dixon, Decommissioning Support Manager T. Hobbs, Decommissioning Director J. Lane, Lead System Engineer, Spent Fuel Pool System Engineering S. McDaniel, Senior Licensing Engineer D. Westcott, DTO Licensing I. Wilson, Manager Planning Decommissioning Transition Organization B. Wunderly, Plant Manager ITEMS OPEN, CLOSED, AND DISCUSSED Opened/Closed 05000302/2014003-01 NCV Decommissioning Trust Fund Expenses Not Used For Decommissioning Planning LIST OF
DOCUMENTS REVIEWED
Action Requests
00685963, 00691179
Audits and Reports
Self Assessment Outline, Maintenance Rule Program, May 2014
Self Assessment Report, Maintenance Rule, May 2014
Self Assessment Review of Decommissioning Trust Fund Invoicing, July 2014
Calculations
N13-0001, Public and Control Room Dose from a Fuel Handling Accident, Revision 0
Engineering Change (EC) Packages
EC 91276, Rev 3, Provide Weather Protection at Containment Cracks and Roof Penetrations,
Information Copy Drawing 30616-85168-018 (Knockout 16I)
Markup Drawing 421-237, (Knockout 16I)
Markup Drawing 521-102 (Knockout 21A)
Markup Drawing 522-012 (Knockout 22A)
Sketch SK-91276-001, Steel Framing Plan for restoration of Knockout 16-I, Revision 3
Sketch SK-91276-002, Rev. 3, Steel Framing Sections and Details for restoration of Knockout
16-I
Sketch SK-91276-003, Rev. 3, Steel Framing Beam Fabrication Details and General Notes for
restoration of Knockout 16-I
EC 93676R0, Spent Fuel Pool Cooling Chillers CHHE-4A/4B
EC 94154, Rev. 0, System Reclassification Resulting from Decommissioning
Procedures
ADM-0101, Rev. 0, Maintenance Rule Program
CR3 Decommissioning NDTF Reimbursement Procedure
ENG-OP-021, Rev. 0, Operation of the Warren Environmental Epoxy Pump Assembly System
Hand Spray Application
PM-106, Rev. 14, Dry-Type Transformers
PM-119, Rev. 29, Maintenance of Electrical Panels and Cabinets
SP-300D, Rev. 1, Defueled Daily Surveillance Log
SP-354B, Rev. 94, Monthly Functional Test of the Emergency Diesel Generator EGDG-1B
Miscellaneous
2014 DTO Maintenance Rule Scoping and Performance Criteria
AI-9003, Rev. 3, System Evaluation, Categorization, and Abandonment, Attachment 4, for the
Chemical Addition and Post-Accident Sampling System (CA-PA)
CR3 Electrical System Modification Summary
CR3 Proposed Electrical Distribution System, 12/18/13
CR3 Simplified Electrical Demo Model
CR3 Total Decommissioning Charges 2013
EDT014-0013, DTO Maintenance Rule System Reclassification, June 23, 2014 and
August 13, 2014
FD-302-700, Rev. 44, Post-Accident Sampling System Drawing, Sheet 1 of 2
FD-302-700, Rev. 8, Post-Accident Sampling System Drawing, Sheet 2 of 2
Maintenance Rule Expert Panel Meeting Minutes, June 26, 2014 and July 17, 2014
Work Order Packages
13384475-02
13346230
218240-01
20887-01
296561-01
296561-02
296561-05
296561-08
296561-09
LIST OF ACRONYMS USED
CFR Code of Federal Regulations
CR-3 Crystal River Unit 3
Duke Energy Duke Energy Florida, Inc.
FSAR Final Safety Analysis Report
IMC Inspection Manual Chapter
IP Inspection Procedure
NRC U.S. Nuclear Regulatory Commission
NCV Non-Cited Violation
PASS Post-Accident Sampling System
SL Severity Level
SPF Spent Fuel Pool
TS Technical Specification
Attachment