IR 05000305/2005003
| ML051330342 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/12/2005 |
| From: | Kozak T NRC/RGN-III/DRP/TSS |
| To: | Lambert C Nuclear Management Co |
| References | |
| IR-05-003 | |
| Download: ML051330342 (44) | |
Text
SUBJECT:
KEWAUNEE NUCLEAR POWER PLANT NRC INTEGRATED INSPECTION REPORT 05000305/2005003
Dear Mr. Lambert:
On March 31, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Kewaunee Nuclear Power Plant. The enclosed inspection report documents the inspection findings which were discussed on March 29, 2005, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, one self-revealed finding of very low safety significance was identified. This finding was determined to involve a violation of NRC requirements.
However, because the violation was of very low safety significance and because the issue was entered into your corrective program, the NRC is treating this issue as a Non-Cited Violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of a 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector Office at the Kewaunee facility.
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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Thomas Kozak, Chief Technical Support Section Division of Reactor Projects Docket No. 50-305 License No. DPR-43 Enclosure: Inspection Report 05000305/2005003 w/Attachment: Supplemental Information cc w/encl: J. Cowan, Executive Vice President, Chief Nuclear Officer Plant Manager Manager, Regulatory Affairs J. Rogoff, Vice President, Counsel & Secretary D. Molzahn, Nuclear Asset Manager, Wisconsin Public Service Corporation L. Weyers, Chairman, President and CEO, Wisconsin Public Service Corporation D. Zellner, Chairman, Town of Carlton J. Kitsembel, Public Service Commission of Wisconsin
SUMMARY OF FINDINGS
IR 05000305/2005003; 01/01/2005 - 03/31/2005; Kewaunee Nuclear Power Plant, Operator
Performance During Non-Routine Evolutions and Events.
This report covers a 3-month period of baseline resident inspection and an announced baseline inspection on radiation protection. The inspections were conducted by the resident and Region III inspectors. The inspection resulted in one self-revealed finding of very low safety significance (Green). The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
Cornerstone: Barrier Integrity
- Green.
A finding of very low safety significance associated with a Non-Cited Violation of the plant operating license was self-revealed during normal plant operations. The Kewaunee Nuclear Power Plant Facility Operating License, as amended stated, The Nuclear Management Company (NMC) is authorized to operate the facility at steady-state reactor core power levels not in excess of 1772 megawatts (thermal). Contrary to this, on January 31, 2005, the 8-hour average thermal power peaked at 1772.07 MWt before being restored to below 1772 MWt. Reactor power was allowed to rise above 1772 MWt because the 8-hr average reactor thermal power indicator on the plant process computer system was not reliable, and the site operating philosophy allowed the 1-minute average and the 15-minute average reactor thermal power indications to exceed 1772 Mwt. Once the 8-hour average was discovered to be in excess of that allowed in the Operating License, operators immediately lowered power to within the licensed limit and entered this issue into the corrective action program.
This violation of the plant operating license was considered greater than minor, because it could affect the barrier integrity cornerstone objective of protecting the integrity of the fuel cladding and was associated with the barrier integrity cornerstone attributes of thermal limits and reactivity control. The finding also involved the crosscutting area of human performance. In accordance with Inspection Manual Chaper (IMC) 0609,
Appendix A, Phase 1, the finding was of very low safety significance. (Section 1R14.1)
Licensee-Identified Violations
No finding of significance were identified.
REPORT DETAILS
Summary of Plant Status
The plant operated at or near full power until February 19, 2005, when a shutdown was initiated due to the licensee determining that all three auxiliary feedwater (AFW) pumps were inoperable. The turbine was taken offline and the reactor shutdown was completed on February 20. The plant reached cold shutdown on February 22 and remained shutdown through the rest of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed a walkdown of the B diesel generator during a period when the train was of increased risk-significance because the A diesel generator was unavailable to determine if the train was correctly aligned to perform its design safety function, as discussed in the appropriate sections of the Technical Specifications (TS)and Updated Safety Analysis (USAR). In preparation for the walkdowns, the inspectors reviewed the system lineup checklists, normal operating procedures, abnormal and emergency operating procedures, and system drawings to determine the correct system lineup. During the walkdown, the inspectors also examined valve positions and electrical power availability to verify that valve and electrical breaker positions were consistent with, and in accordance with, the licensees procedures and design documentation. The inspectors also observed the material condition of the equipment.
Documents reviewed during this inspection are listed in the Attachment. This inspection constituted one sample of the quarterly requirement.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors conducted a complete walkdown of the component cooling water (CCW)system to determine if the system was correctly aligned to perform its design safety function, as discussed in the TS and USAR. This system was selected because of its high relative importance in the licensees probabilistic risk assessment. In preparation for the walk down, the inspectors reviewed the system lineup checklists, normal operating procedures, abnormal and emergency operating procedures, and system drawings to determine the correct system lineup. During the walk down, the inspectors also examined valve positions, electrical power availability, and Control Room control switch positions to verify that valve and electrical breaker positions were consistent with, and in accordance with, the licensees procedures and design documentation. In addition, the inspectors reviewed documents in the coppective action program (CAP)initiated in response to issues identified during a Safety System Design Inspection discussed in Inspection Report (IR) 05000305/2002007 to determine if significant corrective actions (CAs) were being accomplished in a timely manner. The inspectors also observed the material condition of the equipment as part of this inspection.
Documents reviewed in this inspection are listed in the Attachment. This inspection constituted one sample of the semiannual requirement.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
Quarterly Walkdowns (71111.05Q)
a. Inspection Scope
The inspectors performed fire protection walkdowns of the following plant areas, completing nine inspection samples of the quarterly requirement:
- TU-90, diesel generator room A;
- TU-92, diesel generator room B;
- AX-30, relay room;
- various areas protected by Halon systems;
- TU-95A, bus 51/52 area;
- TU-95B, bus 61/62 area;
- TU-22, turbine building operating floor;
- AX-32, cable spreading room; and
- AX-21, bus 1 and 2 room.
During the walkdowns, the inspectors focused on the availability, accessibility, and condition of fire fighting equipment; the control of transient combustibles and ignition sources; and the materiel condition of installed fire barriers. The inspectors selected fire areas for inspection based on the overall contribution to internal fire risk, and the potential to impact equipment that could initiate a plant transient. The inspectors verified that fire response equipment was in the designated location and available for immediate use without obstruction; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and that passive features such as fire doors, dampers, and penetration seals were in satisfactory condition.
Documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
Review of External Flood Protection Measures
a. Inspection Scope
The inspector performed an external flood protection inspection for the lake screen house. This constituted one inspection procedure sample. The inspectors reviewed the USAR and related external flooding analysis to identify external flooding barriers and vulnerabilities. The inspectors reviewed plant procedures and conducted plant walkdowns to determine the adequacy and conditions of existing flood protection measures. As part of this inspection, the inspectors also reviewed licensee resolution of previously identified external flood protection issues. Documents reviewed as part of this inspection are listed in the attachment.
b. Findings
No findings of significance were identified
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors performed an inspection of the heat exchanger performance on the auxiliary building basement fan coil unit 1A, completing one inspection procedure sample. The heat exchanger utilizes service water to cool the auxiliary building basement during normal operation and accident conditions. The inspector observed heat exchanger performance data gathering and software calculation of the heat removal capability of the heat exchanger using obtained performance data. The inspector reviewed test acceptance criteria and compared it against calculated test results. The inspector reviewed heat exchanger performance calculation methodology to ensure that both instrument uncertainty and calculation uncertainty were accounted for in the results to be compared against test acceptance criteria. The inspector also reviewed testing frequency to ensure that it was sufficient consistent with potential for biofouling.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
Quarterly Review of Requalification Activities (71111.11Q)
a. Inspection Scope
The inspectors reviewed a Licensed Operator Requalification Training Program simulator evaluation consisting of one inspection sample of the quarterly requirement.
The inspectors observed crew performance in the simulator setting utilizing an approved simulator scenario that was of sufficient detail and difficulty to evaluate licensed operator performance under simulated emergency conditions. The inspectors observed crew communications, alarm response, use of procedures, control board manipulations, and the ability to take timely action to mitigate plant problems. Crew oversight and direction provided by the Shift Manager was also evaluated. The scenario performance based critique was observed. The training staff provided appropriate observations and suggestions to improve performance to the operating crew.
In addition, the simulation facility functioned properly throughout the observed scenario.
The fidelity of the simulation was appropriate for all conditions and malfunctions simulated by the machine.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
Routine Quarterly Resident Review (71111.12Q)
a. Inspection Scope
The inspectors reviewed the implementation of the Maintenance Rule for the systems listed below, completing two inspection samples of the quarterly requirement:
- incore instrumentation; and
- Foxboro H-Line process control equipment.
The inspectors verified that the licensee identified, entered, and scoped component and equipment failures within the maintenance rule requirements. The inspectors also verified that the systems and equipment were properly categorized and classified as (a)(1) or (a)(2) in accordance with 10 CFR 50.65. The inspectors reviewed a sample of maintenance work orders (WOs), action requests, functional failure evaluations, unavailability records, and a sample of CAP reports to verify that the licensee identified issues related to the Maintenance Rule at an appropriate threshold and that CAs were appropriate. Additionally, the inspectors reviewed the licensees performance criteria to verify that the criteria adequately monitored equipment performance. Documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensees management of plant risk during emergent maintenance activities or during activities where more than one significant system or train was unavailable. The activities were chosen based on their potential impact on increasing the probability of an initiating event or impacting the operation of risk-significant equipment. The inspections were conducted to determine whether evaluation, planning, control, and performance of work were done in a manner to reduce the risk and minimize the duration where practical, and that contingency plans were in place where appropriate.
The licensees daily configuration risk assessment records, observations of operator turnover and planning meetings, and observations of work in progress, were used by the inspectors to determine whether the equipment configurations were properly listed, that protected equipment was identified and being properly controlled where appropriate, that work was being conducted properly, and that significant aspects of plant risk were being communicated to the necessary personnel.
In addition, the inspectors reviewed CAP entries to determine whether problems encountered during the activities were being entered with the appropriate characterization and significance. Documents reviewed during this inspection are listed in the Attachment.
The inspectors completed four samples of this inspection requirement by reviewing the following activities:
- compensatory actions for internal flooding concerns;
- compensatory actions for AFW pump suction concerns;
- protection of B train safeguards equipment during outage maintenance on A train components; and
- actions taken upon discovery of a B train control room post accident recirculation system operability issue while the A train diesel generator was inoperable.
b. Findings
No findings of significance were identified that will be documented in this report. For the inspection samples regarding compensatory actions for internal flooding concerns and AFW pump suction concerns, any potential findings have been addressed in IR 05000305/2005002, a pilot inspection which took place during the same time period.
1R14 Operator Performance During Non-Routine Evolutions and Events
.1 Licensed Reactor Thermal Power Exceeded During Normal Plant Operations
a. Inspection Scope
The inspectors reviewed the conditions leading to and operator response to a condition where reactor thermal power exceeded the licensed thermal power limit for an 8-hour average.
b. Findings
Introduction:
A finding of very low safety significance associated with a non-cited violation (NCV) of the plant operating license was self-revealed during normal plant operations. On January 31, 2005, the operators received an alarm indicating that they had exceeded 1772 megawatts thermal (MWt) for an 8-hour average. Exceeding an 8-hour average of 1772 MWt was a violation of the plant operating license. This finding was also associated with the cross-cutting area of human performance because it involved operators failing to be attentive to and analyzing all of their indications of reactor power in order to maintain the power at less than or equal to the the licensed limit.
Description:
On January 31, 2005, the Control Room received an alarm for Reactor Thermal Power High. This alarm was set to come in whenever the 8-hour average reactor power exceeded 1772 MWt, the licensed thermal power limit. Reactor power was allowed to rise above 1772 MWt average because some indicators on the plant process computer system (PPCS) that are normally used to verify compliance with the plant licensed thermal power limitations were not reliable. This unreliability was caused by the performance of a calibration procedure on a feedwater flow transmitter which provides inputs to the PPCS for the reactor thermal output calculation. Surveillance Procedure SP-05A-034C-1 Feed water Slow Transmitter Channel 1 (Red) Calibration was performed and it affected the reactor thermal power calculations being performed by the PPCS, by providing artificially low feedwater flow data to the PPCS which was then used to calculate the 8-hour average reactor thermal power.
When this artificially low data no longer contributed to the 8-hour average, the calculated 8-hour average, as displayed on the control room PPCS monitors rapidly increased to the actual thermal power level. Shortly thereafter, the reactor thermal power 8-hour average read 1772.03 MWt and the Reactor Thermal Power High alarm was received in the control room. Upon receipt of the alarm, the control room operators entered the Alarm Response Procedure for the Reactor Thermal Power High alarm and immediately reduced reactor thermal power below 1772 megawatts in accordance with that procedure. During this occurrence, the Reactor Thermal Power 8-hour average peaked at 1772.07 MWt.
During this time frame, the on-shift operating crew was aware that the reactor thermal power 8-hour average data being displayed on control room PPCS monitors was unreliable. However, other indications of reactor thermal power, including PPCS reactor thermal power 15-minute average data was reliably being displayed on the control room PPCS monitors. The reactor thermal power 15-minute average data clearly indicated a reactor thermal power above 1772 MWt. However, no operator action was taken to immediately reduce thermal power below 1772 MWt. In addition, when this 15 minute average data showed reactor thermal power moving below 1772 MWt thermal, a dilution was performed to increase reactor thermal power above 1772 MWt. These operator actions were due to a site operating philosophy which allowed the 1 minute average and the 15 minute average reactor thermal power to exceed 1772 megawatts.
Analysis:
The inspectors determined that, in accordance with Appendix B of IMC 0612, failure to maintain the reactor thermal power 8-hour average below 1772 MWt, as required by the plant Operating License, was a licensee performance deficiency and was considered greater than minor because it could affect the fuel cladding barrier.
Thus, it degraded the barrier integrity cornerstone objective and was associated with the cornerstone attributes of thermal limits and reactivity control. The inspectors evaluated the significance of this finding using IMC 0609, Appendix A, Phase 1, where findings affecting only the fuel cladding screen out as green or of very low safety significance.
This finding was also associated with the cross-cutting area of human performance because it involved operators failing to be attentive to and analyzing all of their indications of reactor power in order to maintain the power at less than or equal to the licensed limit.
Enforcement:
Condition 2.C.(1) of the Kewaunee Operating License as Amended states The NMC is authorized to operate the facility at steady-state reactor core power levels not in excess of 1772 megawatts (thermal). Contrary to this, the 8-hour average thermal power peaked at 1772.07 MWt before being restored to below 1772 MWt.
Exceeding the power limitations specified in the plant Operating License is a violation.
This violation of the conditions of the plant Operating License is of low safety significance, in accordance with IMC 0609, Appendix A, Phase 1. Therefore, this violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy (NCV 05000305/2005003-01). Once the 8-hour average was discovered to be in excess of that allowed in the Operating License, operators immediately lowered power to within the licensed limit and entered this issue into the corrective action program as CAP 025063, CAP 025257, and CAP 025263.
.2 Lake Water Intrusion into the Steam Generators
a. Inspection Scope
The inspectors completed one inspection sample by evaluating the licensees actions leading up to and as a result of lake water intrusion into the steam generators. The inspectors reviewed operator actions in the control room, control room logs and strip charts, interviewed station personnel, attended briefings in the outage control center, and attended the initial event investigation teams exit meeting with plant management.
The inspectors evaluated the initiating cause of the lake water intrusion, and the control room operating teams response to the event. The inspectors also reviewed the stations CAP to determine if this event had been properly addressed. Finally, the inspectors reviewed the licensees technical evaluation of the short and long term effects of the event. The documents reviewed during this inspection are listed in the to this report.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following operability evaluations, completing two inspection samples:
- seismic qualification of the plant process computer system (PPCS) input/output racks; and
- AFW pump discharge pressure switches may not protect the pumps during a loss of suction.
Note: Two other baseline samples of this inspection requirement were conducted as part of IR 05000305/2005002, a pilot temporary instruction inspection which took place during the same time period.
The inspectors reviewed design basis information, the USAR, TS requirements, seismic evaluation work sheets, and licensee procedures to verify the technical adequacy of the operability evaluations. In addition, the inspectors verified that compensatory measures were implemented, as required, for the AFW issue. For the AFW switch issue, the inspectors also reviewed 10 CFR 50.72 Event Notification 41406 by which the licensee reported the condition. Documents reviewed during this inspection are listed in the
.
b. Findings
No findings of significance were identified that will be documented in this report. For the inspection sample regarding operability of the AFW pumps, any potential findings have been addressed in IR 05000305/2005002, a pilot temporary instruction inspection which took place during the same time period.
1R16 Operator Workarounds
Review of Selected Operator Workarounds
a. Inspection Scope
The inspectors reviewed new emergent, risk-significant, operator compensatory action plans to determine whether they created significant adverse consequences regarding the reliability, availability, and operation of accident mitigating systems. The inspectors also assessed the effects of the workarounds on the ability to implement abnormal and emergency response procedures in a correct and timely manner, whether any unrecognized consequences were introduced, and whether human performance error probabilities were properly considered. Documents reviewed during this inspection are listed in the Attachment. The inspectors completed two samples of this inspection requirement by reviewing the following:
- planned operator actions in response to internal flooding; and
- planned operator actions in response to tornados with respect to AFW pump suction.
b. Findings
No findings of significance were identified that will be documented in this report. For the inspection samples regarding compensatory actions for internal flooding concerns and AFW pump suction concerns, any potential findings have been addressed in IR 05000305/2005002, a pilot temporary instruction inspection which took place during the same time period.
1R17 Permanent Plant Modifications
Annual Review of On-Line Modification (71111.17A)
a. Inspection Scope
The inspectors reviewed the engineering analyses, design information and modification documentation for the replacement of the PPCS. This system performs calculations on the performance of the reactor and on reactor power levels. This inspection constituted one inspection procedure sample. The inspection activities included, but were not limited to, verification and review of the following parameters associated with this modification: structural design classification; fire protection combustible loading; installation impacts on plant operation; quality classification; environmental qualification; safety classification; seismic qualification; failure mode potentials; and the associated 10 CFR 50.59 screening analysis. Additionally, the inspectors observed portions of the installation and testing of the PPCS, reviewed acceptance testing results, and reviewed CAP documents associated with the design change and subsequent operation to verify that the licensee identified and documented problems at an appropriate threshold.
Since the replacement activity resulted in a temporary loss of the Emergency Response Data System and Safety Parameter Display System, the licensee reported the initiation and completion of the outage via 10 CFR 50.72 in Event Notification 41309 on January 5 and January 20, 2005. Documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance testing activities associated with the following scheduled and emergent work activities, completing four inspection samples:
- changeout of a average reactor coolant system temperature instrumentation module;
- routine maintenance of CCW pump 1A;
- replacement of the solenoid operator for the service water supply valve to the A diesel generator, SW-301A; and
- changeout of the plant process computer system / safety parameter display system.
The inspectors verified that the testing was adequate for the scope of the maintenance work performed. The inspectors reviewed the acceptance criteria of the tests to ensure that the criteria was clear and that testing demonstrated operational readiness consistent with the design and licensing basis documents. Documents reviewed during this inspection are listed in the Attachment.
The inspectors attended pre-job briefings to verify that the impact of the testing was appropriately characterized. The inspectors also observed the performance of testing to verify the procedure was followed and that all testing prerequisites were satisfied.
Following the completion of tests, the inspectors walked down the affected equipment to verify removal of the test equipment and to ensure the equipment could perform the intended safety function following the test. The inspectors also reviewed the completed test data to ensure the test acceptance criteria were met for the post maintenance testing.
b. Findings
No findings of significance were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors observed the licensees performance during a forced outage which began on February 19, 2005, and continued through the end of the inspection period.
This activity represented one partial inspection sample with more inspection to follow in the next inspection quarter.
The inspection consisted of reviews of outage schedules, outage risk assessments, protected equipment designation, and periodic observations of plant and control room outage activities. Specifically the inspectors determined whether the licensee effectively managed elements of shutdown risk pertaining to reactivity control, decay heat removal, inventory control, electrical power control, and containment integrity.
The inspectors performed the following activities on a daily or frequent basis:
- attended outage control center update meetings to assess whether licensee employees had adequate knowledge of outage risk activities, the effects of schedule changes on risk, and the current status of protected equipment;
- attended operating crew briefings to assess whether operators had adequate knowledge of the plant status, with emphasis on those activities which would affect shutdown risk;
- performed walkdowns of the main control room to observe the alignment of systems important to shutdown risk;
- reviewed licensee CAP documents to determine whether shutdown risk issues had been entered into the system with an appropriate characterization and significance level, and that they were receiving the appropriate attention and priority for resolution;
- reviewed the shiftly Shutdown Safety Assessment Checklist to determine whether outage risk and defense-in-depth status had been correctly evaluated; and
- performed walkdowns of the turbine building and auxiliary building to monitor ongoing work activities.
Additionally, the inspectors performed the following specific activities:
- observed portions of the plant shutdown and establishing of the initial cooldown with AFW;
- establishing of residual heat removal operation, and continued cooldown to cold shutdown conditions;
- participated in an internal inspection of the circulating water expansion joints; and
- observed portions of draining and filling operations of the steam generators.
During the outage, the licensee implemented a number of recovery and improvement initiatives to address weaknesses, some of which led to the shutdown. The inspectors observed many of the licensees actions and monitored progress toward resolving restart restraints. The inspectors activities included:
- attending numerous management-level briefings on aspects of the recovery plan;
- reviewing CAP documents related to the plan;
- attending a training session designed to improve licensee operability decisions and documentation; and
- attending challenge board meetings to determine whether technical issues had been adequately resolved.
Documents reviewed as part of this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed and reviewed the surveillance testing results for the following surveillances, completing four inspection samples:
- diesel generator A monthly test;
- turbine trip mechanism monthly test;
- turbine first stage pressure instruments monthly test; and
- engineered safety features train B quarterly logic channel test.
Note: Six other baseline samples of this inspection requirement were conducted as part of IR 05000305/2005002, a pilot temporary instruction inspection which took place during the same time period.
The inspectors verified that the equipment could perform the intended safety function and that the surveillance tests satisfied the requirements contained in plant TS and licensee procedures. The inspectors reviewed the surveillance tests to verify that the tests adequately demonstrated operational readiness consistent with plant design and licensing basis documents, and that the testing acceptance criteria were well documented and appropriate to the circumstances. Documents reviewed during the inspection are listed in the Attachment.
The inspectors observed portions of the test to verify the following attributes:
performance of the test in accordance with prescribed procedures; completion of test procedure prerequisites; and verification that the test data was complete, appropriately verified, and met the acceptance criteria of the test. Following the completion of the tests, when applicable, the inspectors walked down the affected equipment to verify test equipment removal and to confirm the equipment tested was in an operable condition.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed the modification documentation and associated 10 CFR 50.59 evaluation for temporary plant modification TCR 02-01, for installation of a travel limiter device on valve CC-302, completing one inspection procedure sample.
The inspectors verified that the temporary modification did not adversely impact other safety-related equipment and that the modification was controlled in accordance with the licensees administrative procedures. The inspectors also verified that the modification did not affect system operability or availability. In addition, the inspectors reviewed condition reports to verify that temporary modification problems were entered into the CAP with the appropriate significance characterization.
The inspectors also reviewed Event Notification 41539, initiated by the licensee on March 28, 2005, to report that an unrecognized condition of inoperability had existed before the temporary modification had been installed.
b. Findings
No findings of significance were identified. The failure to previously report the condition of inoperability was considered a minor issue.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
.1 Inspection Planning
a. Inspection Scope
The inspectors reviewed the USAR to identify applicable radiation monitors associated with measuring transient high and very high radiation areas including those used in remote emergency assessment. The inspectors identified the types of portable radiation detection instrumentation used for job coverage of high radiation area work including instruments used for underwater surveys, fixed area radiation monitors (ARMs) used to provide radiological information in various plant areas and continuous air monitors used to assess airborne radiological conditions and consequently work areas with the potential for workers to receive a 50 millirem or greater committed effective dose equivalent (CEDE). Contamination monitors, whole body counters and those radiation detection instruments utilized for the release of personnel and equipment from the radiologically restricted area (RRA) were also identified.
These reviews represented two inspection samples.
b. Findings
No findings of significance were identified.
.2 Walkdowns of Radiation Monitoring Instrumentation
a. Inspection Scope
The inspectors conducted walkdowns of selected ARMs in the Auxiliary Building and the Reactor Containment Building to verify they were located as described in the USAR and were optimally positioned relative to the potential source(s) of radiation they were intended to monitor. Walkdowns were also conducted of those areas where portable survey instruments were calibrated/repaired and maintained for radiation protection (RP)staff use to determine if those instruments designated ready for use were sufficient in number to support the radiation protection program, had current calibration stickers, were operable, and were in good physical condition. Additionally, the inspectors observed the licensees instrument calibration units and the radiation sources used for instrument checks to assess their material condition and discussed their use with RP staff to determine if they were used adequately. Licensee personnel demonstrated the methods for performing source checks of portable survey instruments and for source checking personnel contamination and portal monitors used at the egress to the RRA.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.3 Calibration and Testing of Radiation Monitoring Instrumentation
a. Inspection Scope
The inspectors selectively reviewed radiological instrumentation associated with monitoring transient high and/or very high radiation areas, instruments used for remote emergency assessment, and radiation monitors used to identify personnel contamination and for assessment of internal exposures to verify that the instruments had been calibrated as required by the licensees procedures, consistent with industry and regulatory standards. The inspectors also reviewed alarm setpoints for selected ARMs, for personnel contamination monitors and for portal (egress) monitors to verify that they were established consistent with the USAR or TS, as applicable, and were consistent with industry practices and regulatory guidance. Specifically, the inspectors reviewed calibration procedures and the most recent calibration records and/or source output verification documents for the following radiation monitoring instrumentation and instrument calibration equipment:
- Containment High Level (Wide Range) Radiation Monitors (channels R-40/41);
- Charging Pump Room ARM (channel R-4);
- In-Core Instrument Seal Table ARM (channel R-7);
- New Fuel Pit Area Monitor (channel R-10);
- Portable Survey Instrument used for Neutron Surveys (Rem Ball);
- Portal Monitor used at RRA Egress;
- Personnel Contamination Monitor used at RRA egress;
- Portable Survey Instruments used for Underwater Surveys (two instruments);
- Calibrators used to Calibrate Portable Survey Instruments and ARMs (two calibrators) and the associated instruments used to measure Calibrator output; and
- Whole Body Counter.
The inspectors determined what actions were taken when, during calibration or source checks, an instrument was found significantly out of calibration or exceeded as-found acceptance criteria. Should that occur, the inspectors verified that the licensees actions would include a determination of the instrumentss previous usages and the possible consequences of that use since the prior calibration. The inspectors also discussed with RP staff the 10 CFR Part 61 source term (radionuclide mix) to determine if the calibration sources used were representative of the plant source term and that difficult to detect nuclides were scaled into whole body count dose determinations.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.4 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed licensee CAP documents and any special reports that involved personnel contamination monitor alarms due to personnel internal exposures to verify that identified problems were entered into the CAP for resolution. Licensee self-assessments, field observations and CAPs were also reviewed to verify that problems with radiological instrumentation or self-contained breathing apparatus were identified, characterized, prioritized, and resolved effectively using the CAP.
The inspectors reviewed CAP reports related to exposure significant radiological incidents that involved radiation monitoring instrument deficiencies since the last inspection in this area, as applicable. Members of the radiation protection staff were interviewed and corrective action documents were reviewed to verify that follow-up activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk based on the following:
- 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; and
- identification and implementation of effective CAs.
The inspectors determined if the licensees self-assessment, audit and/or field observation activities completed for the 2-year period that preceded the inspection were identifying and addressing repetitive deficiencies or significant individual deficiencies in problem identification and resolution, as applicable.
These reviews represented three inspection samples.
b. Findings
No findings of significance were identified.
.5 Radiation Protection Technician Instrument Use
a. Inspection Scope
The inspectors selectively verified that calibrations for those instruments recently used and for those designated for use had not lapsed. The inspectors reviewed instrument logs for the first two and one-half months of 2005 to verify that response checks of portable survey instruments and checks of instruments used for unconditional release of materials and workers from the RRA were completed prior to instrument use or daily, as required by the licensees procedure. The inspectors also discussed instrument calibration methods and source response check practices with radiation protection staff and observed staff compete instrument source checks prior to use.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.6 Self-Contained Breathing Apparatus (SCBA) Maintenance/Inspection and User Training
a. Inspection Scope
The inspectors reviewed aspects of the licensees respiratory protection program for compliance with the requirements of Subpart H of 10 CFR Part 20 and to determine if self-contained breathing apparatus (SCBA) were properly maintained and ready for emergency use. The inspectors reviewed the status and surveillance records of SCBAs staged for emergency use in various areas of the plant and assessed the licensees capability for refilling and transporting SCBA air bottles to and from the control room during emergency conditions. The inspectors verified that all control room staff designated for the active on-shift duty roster including those individuals on the stations fire brigade were trained, respirator fit tested, and medically certified to use SCBAs.
Additionally, the inspectors reviewed respiratory protection equipment qualification records for the emergency response organizations radiological emergency teams and for other key emergency responders and repair teams to determine if a sufficient number of staff were qualified to fulfill emergency response positions to meet the requirements of 10 CFR 50.47. The inspectors also reviewed the respiratory protection training lesson plan to assess its overall adequacy consistent with Subpart H of 10 CFR Part 20 and to verify that personal SCBA air bottle change-out was adequately covered as part of the training.
The inspectors walked down the bottled air supply rack and spare air bottle stations located outside the main control room, and inspected SCBA equipment maintained in the control room and SCBA equipment staged for emergency use in various other areas of the plant. During the walkdowns, the inspectors examined several SCBA units to assess their material condition, to verify that air bottle hydrostatic tests were current, and to verify that bottles were pressurized to meet procedural requirements. The inspectors reviewed records of SCBA equipment inspection and testing and observed an RP technician demonstrate the methods used to conduct the inspections and functional tests to determine if these activities were performed consistent with procedure and the equipment manufacturers recommendations. The inspectors also ensured that the required, periodic air cylinder hydrostatic testing was documented and up to date, and that the Department of Transportation required retest air cylinder markings were in place for several randomly selected SCBA units and spare air bottles. Additionally, the inspectors reviewed the vendor training certificate for the individual that performed the repair of SCBA pressure regulators to determine if those personnel that performed maintenance on components vital to equipment function were qualified.
These reviews represented two inspection samples.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that issues were entered into the licensees CAP system at an appropriate threshold, that adequate attention was given to timely CAP resolution, and that adverse trends were identified and addressed. The inspectors also reviewed all CAP documents written by licensee personnel during the inspection quarter. Issues entered into the licensees CAP system, directly or indirectly, as a result of the inspectors observations or questions are included at the end of the list of documents in the Attachment.
b. Findings
There were no findings of significance
.2 Annual Sample
Internal Flooding Modification and Operability Recommendations Introduction The inspectors reviewed a modification that had been issued to address internal flooding vulnerabilities documented as CAPs in the licensees problem identification and resolution program. This sample was selected to verify that the licensee was adequately addressing CAs. Documents reviewed as part of this inspection are listed in the Attachment. This activity constituted one sample of this inspection requirement.
a.
Prioritization and Evaluation of Issues
- (1) Inspection Scope The inspectors considered the licensees evaluation and disposition of performance issues, and application of risk insights for prioritization of issues by reviewing the modification to install floor sweeps, sill plates and weather stripping to make specific doors as water tight as possible.
- (2) Issues The inspectors determined that licensee CAs were based on a qualitative assessment of risk. For the issues reviewed, the inspectors did not find any discrepancies with the apparent risk and the categorization assigned by the licensee. Planned CAs did not adversely impact the immediate operability of associated equipment.
b.
Effectiveness of CAs
- (1) Inspection Scope The inspectors reviewed the modification, multiple CAPs, and three revisions of the same operability recommendation for various barriers and drain paths protecting Class I structures, systems and components to determine if CAs addressed generic implications and were appropriately focused to correct the problem.
- (2) Issues The inspectors determined that planned CAs identified in the modification, CAPs and the final revision of the operability recommendation appeared to be adequate for and were focused on the specific internal flooding issues addressed. However, effectiveness of the pending CAs rely on followup assessments (i.e., 10 CFR 50.59 reviews and a comprehensive flooding analysis) to verify the adequacy of completed CAs. Finally, two additional modifications were in the process of being written and implemented to fully address remaining internal flooding issues.
On March 15, 2005, the licensee initiated Event Notification 41496 in accordance with 10 CFR 50.72 to report that it had determined that the plant design for flooding events may not mitigate the consequences of piping system failures. Any findings associated with this issue have been documented in IR 05000305/2005002, a pilot temporary instruction inspection that occurred at the same time as this inspection.
4OA3 Event Followup
.1 (Closed) Licensee Event Reports (LERs) 05000305/2004-001-00 and 05000305/2004-
001-01: Blocked Lube Oil Coolers to Safety Injection Pumps Force Plant Shutdown This event has been discussed extensively in previous IRs. The original LER was opened in IR 05000305/2004002, Section 4OA3.2. The event was the main subject of Special IR 05000305/2004003, in which it was considered Unresolved Item 05000305/2004003-01. The Unresolved Item was closed and two NCVs for findings of very low safety significance were issued in IR 05000305/2004004, Sections 4OA3.1, 4OA3.2, and 4OA3.3. At that time, the LER remained open pending issuance of a revision which discussed past operability. The revised LER was issued on September 14, 2004, and contained the expected new information. No new significant concerns not already addressed by the previous findings were identified. The original LER and its revision are both closed.
.2 (Closed) LER 05000305/2004-003-01: Control Room Boundary Door Found Ajar -
Accident Analysis Assumptions Impacted - Personnel Error This event was previously discussed in IR 05000305/2004009, Sections 4OA3.1 and 4OA7, and was considered to be a licensee-identified NCV of very low safety significance. This issue was previously entered into the licensees corrective action program as CAP 022205. The revision to the LER added analysis information relative to the consequences the door being open in the case of smoke or toxic gas. No new issues of significance were identified. This LER is closed.
.3 (Closed) LER 05000305/2004-004-00: Procedure Deficiency Results in Automatic
Containment Ventilation Isolation Being Disabled Contrary to Technical Specifications This event was previously discussed in IR 05000305/2004009, Section 1R20 b.3, and was considered to be a self-revealed NCV and finding of very low safety significance (NCV 05000305/2004009-07). The issue was previously entered into the licensees corrective action program as CAP 024107. There were no new concerns identified in the LER. This LER is closed.
.4 (Closed) LER 05000305/2004-005-00: Safety Injection Accumulator Isolation Valve
Position During Heatup Violates Technical Specifications - Procedure Deficiency This event was previously discussed in IR 05000305/2004009, Section 4OA7, and was considered to be a licensee-identified NCV of very low safety significance. The issue was previously entered into the licensees corrective action program as CAP 024241.
There were no new concerns identified in the LER. This LER is closed.
.5 Conduct of an Unauthorized Test
a. Inspection Scope
On January 23, 2005, an individual conducted an unauthorized activity to determine if an oxygen deficient environment could be created if a situation were to occur involving liquid nitrogen used for radiological analysis equipment. The individual established remote monitoring for oxygen concentrations and then established conditions to allow nitrogen to fill a closed laboratory space (Radiological Analysis Facility countroom). An oxygen deficient environment was established that was immediately dangerous to life and health. Oxygen concentrations in the room fell to as low as approximately 10%
(normal oxygen levels are approximately 21%).
This unauthorized activity was conducted without approve procedures. The licensee determined that conditions existed during this event which met the criteria of a Notification of Unusual Event. Once discovered, the licensee reported this condition to the NRC. The inspectors walked down the area of the unauthorized activity as well as the surrounding area, interviewed senior plant management on the details of this activity, reviewed plant documentation and reports generated as result of this activity, observed that plant personnel briefings on this activity and reviewed plant follow-up actions as a result of this activity.
In addition, based on the investigation of the above event, it was discovered that the same individual had previously released liquid nitrogen in the auxiliary building elevator, as part of the same data collection activity. This release may also have been at the levels of immediately dangerous to life and health. This previous incident occurred on January 22, 2005.
Both of these events were reported to the NRC under 10 CFR 50.72 as an after-the-fact emergency condition (Unusual Event) as Event Notification 41398 on February 10 and February 24, 2005.
b. Findings
No findings of significance were identified during this inspection. A follow-up inspection of this activity will be performed during the next Emergency Planning inspection.
.6 Technical Specification Required Shutdown due to Inoperable AFW Pumps
On February 20, 2005, the licensee initiated Event Notification 41423 in accordance with 10 CFR 50.72 when it determined that a high energy line break in the turbine building could affect the AFW pump common suction line from the condensate storage tank.
The inspectors reviewed the event notification for completeness and accuracy and monitored the licensees subsequent actions to resolve the issue. However, any findings associated with this issue have been addressed in IR 05000305/2005002 for a pilot temporary instruction inspection which was accomplished at the same time as this inspection.
.7 Reactor Protection System Actuation on Low Steam Generator Level While Shutdown
On February 20, 2005, the licensee initiated Event Notification 41425 in accordance with 10 CFR 50.72 when it experienced a valid actuation of the reactor protection system on low steam generator level due to inadequate control of temperature and level during a plant shutdown and cooldown. The reactor was already shutdown at the time. Thus the event did not involve more than minor risk and was not reviewed by this inspection beyond checking to determine that the event was properly reported and entered into the licensees CAP.
4OA4 Cross-Cutting Aspects of Findings
The finding described in Section 1R14.1 of this report had, as its primary cause, a human performance deficiency in that the failure to adequately monitor reactor thermal power and rapidly return power to below the licensed thermal power limit when it exceeded it during transients, led to exceeding the limit for the average of an 8-hour period.
4OA6 Meetings
.1 Exit Meeting
On March 29, 2005, the resident inspectors presented the inspection results to Mr. C. Lambert and other members of licensee management. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
An interim exit meeting was conducted for:
- Occupational radiation safety program for radiation monitoring instrumentation and protective equipment with Mr. C. Lambert on March 18, 2005.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Nuclear Management Company, LLC
- C. Lambert, Site Vice President
- P. Harden, Improvements Programs Director
- K. Hoops, Site Director
- K. Davison, Plant Manager
- P. Anderson, Outage & Scheduling Manager
- L. Armstrong, Site Engineering Director
- S. Baker, Radiation Protection Manager
- L. Blocker, Operations Manager
- W. Flint, Chemistry Manager
- W. Hunt, Maintenance Manager
- G. Salamon, Regulatory Affairs Manager
NRC Personnel
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000305/2005003-01 NCV Licensed Reactor Thermal Power Exceeded During Normal Plant Operations (Section 1R14.1)
Closed
- 05000305/2004-001-00 LER Blocked Lube Oil Coolers to Safety Injection Pumps Force Plant Shutdown (Section 4OA3.1)
- 05000305/2004-001-01 LER Blocked Lube Oil Coolers to Safety Injection Pumps Force Plant Shutdown (Section 4OA3.1)
- 05000305/2004-003-01 LER Control Room Boundary Door Found Ajar - Accident Analysis Assumptions Impacted - Personnel Error (Section 4OA3.2)
- 05000305/2004-004-00 LER Procedure Deficiency Results in Automatic Containment Ventilation Isolation Being Disabled Contrary to Technical Specifications (Section 4OA3.3)
- 05000305/2004-005-00 LER Safety Injection Accumulator Isolation Valve Position During Heatup Violates Technical Specifications -
Procedure Deficiency (Section 4OA3.4)
- 05000305/2005003-01 NCV Licensed Reactor Thermal Power Exceeded During Normal Plant Operations (Section 1R14.1)
Discussed
None