IR 05000305/2007003
| ML072260487 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/14/2007 |
| From: | Jamnes Cameron NRC/RGN-III/DRP/RPB5 |
| To: | Christian D Dominion Energy Kewaunee |
| References | |
| IR-07-003 | |
| Download: ML072260487 (50) | |
Text
ust 14, 2007
SUBJECT:
KEWAUNEE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000305/2007003 AND NOTICE OF VIOLATION
Dear Mr. Christian:
On June 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Kewaunee Power Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on July 11, 2007, with Ms. L. Hartz 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, the NRC has determined that a severity Level IV violation of NRC requirements occurred. The violation was evaluated under the NRC traditional enforcement process in accordance with the NRC Enforcement Policy included on the NRCs Web site at www.nrc.gov; select What We Do, Enforcement, then Enforcement Policy.
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because this issue was not entered into your corrective action program as you disagree with the violation.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
Based on the results of this inspection, the NRC has also identified a finding of very low safety significance, which involved a violation of NRC requirements. Because this finding was of very low safety significance and was entered into your corrective action program, the NRC is treating that issue as a non-cited violation (NCV), in accordance with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, 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 - 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 at the Kewaunee Power Station.
In accordance with 10 CFR 2.390 of the NRC's "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 System (PARS)
component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jamnes L. Cameron, Chief Branch 5 Division of Reactor Projects Docket No. 50-305 License No. DPR-43 Enclosure: Inspection Report 05000305/2007003 w/Attachment: Supplemental Information cc w/encl: L. Hartz, Site Vice President C. Funderburk, Director, Nuclear Licensing and Operations Support T. Breene, Manager, Nuclear Licensing L. Cuoco, Esq., Senior Counsel D. Zellner, Chairman, Town of Carlton J. Kitsembel, Public Service Commission of Wisconsin State Liaison Officer, State of Wisconsin
SUMMARY OF FINDINGS
IR 05000305/2007003; 04/01/2007 - 06/30/2007; Kewaunee Power Station. Operability
Evaluations, and Surveillance Testing.
This report covers a three-month period of inspection by resident inspectors and announced inspections by regional specialists. Two Green findings, one with an associated non-cited violation (NCV) and one with a cited severity level IV violation were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a finding having very low safety significance and an associated Severity Level IV, Cited Violation of 10 CFR 50.59 while reviewing unresolved items URI 05000305/2006003-04, Adequacy of Compensatory Actions for Potential Turbine Missile Strike of Control Room Ventilation Cooling; and URI 05000305/2006016-01, Adequacy of 10 CFR 50.59 Screening for Procedure Change. Specifically, the licensee failed to properly interpret design and licensing basis requirements associated with protection against external events and as a result did not perform a 10 CFR 50.59 evaluation. The cause of this finding is related to the cross-cutting area of problem identification and resolution because the licensee had similar prior problems that, if effectively evaluated and resolved, could have prevented this issue. (P.1(c))
This finding was determined to be more than minor because the inspectors determined that the procedure change would have ultimately required NRC approval. The procedure changes, in the form of compensatory operator actions, adversely impacted the operation of control room recirculation system following a tornado. A Phase 1 significance determination of this finding using IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," using the Severe Weather Screening Criteria questions was completed. Since the loss of the control room recirculation system would not result in an initiating event or degrade two or more trains of a multi-train safety system, the issue screened as
- Green.
(Section 1R15.a.1)
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a finding having very low safety significance and an associated non-cited Violation of 10 CFR 50, Appendix B, Criterion V, Instructions ,
Procedures, and Drawings,while reviewing surveillance testing procedures for the auxiliary building special ventilation zone (Zone SV). Specifically, the licensee procedure for tracking the amount of in-leakage into the Zone SV did not have adequate criteria to capture degraded conditions, nor ensure that the acceptance criteria reflected the design requirements of the system. The cause of this finding is related to the cross-cutting area of problem identification and resolution because the licensee failed to properly evaluate multiple condition reports for operability and extent of condition. (P1(c))
This finding was determined to be more than minor because, if left uncorrected, the failure to evaluate barrier breaches that did not have breach permits could become a more significant safety concern. Specifically, if left unmonitored the breaches without barrier permits could potentially exceed the allowable design limits. The finding was evaluated using IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. The answer to Question 1 in the Significance Determination Process Phase 1 Screening Worksheet in the Containment Barrier Cornerstone column was yes; therefore, this finding is of very low safety significance (Green). Corrective actions to date included revisions to procedure FPP-08-09, to track barrier breaches that result from degraded conditions and provide conservative acceptance criteria. (Section 1R22.b)
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Kewaunee operated at full power for the entire inspection period except for brief reductions in power to conduct planned surveillance testing activities with the following exceptions:
- on April 29 operators commenced a shutdown of the unit due to outside air temperature exceeding limits for emergency diesel generator (EDG) operability.
Power was reduced to approximately 90 percent when air temperatures lowered to a point where EDG operability was restored. Power was increased to full power later the same day;
- on May 3 operators reduced reactor power to 94 percent for heater drain pump repairs. The reactor was returned to full power on May 7; and
- on June 23 operators reduced reactor power to 46 percent for condensate pump and heater drain pump repairs, and to conduct auxiliary feedwater (AFW) and turbine stop valve testing. The reactor was returned to full power on June 24,
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R01 Adverse Weather Protection
a. Inspection Scope
The inspectors performed a detailed review of the licensees procedures and a walkdown of two systems to observe the licensees preparations for adverse weather, including high temperatures and high winds. The inspectors focused on plant specific design features for the systems and implementation of the procedures for responding to or mitigating the effects of adverse weather. Inspection activities included, but were not limited to, a review of the licensees adverse weather procedures, preparations for summer season, and a review of analyses and requirements identified in the Updated Safety Analysis Report (USAR). The inspectors also verified that operator actions specified by plant procedures were appropriate. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors evaluation of the readiness for seasonal susceptibilities for the following areas counts as two inspection samples:
- seasonal hot weather preparations; and
- transformers and switch yard in preparation for a high wind advisory.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial walkdowns of accessible portions of trains of risk-significant mitigating systems equipment. The inspectors reviewed equipment alignment to identify any discrepancies that could impact the function of the system and potentially increase risk. Identified equipment alignment problems were verified by the inspectors to be properly resolved. The inspectors selected redundant or backup systems for inspection during times when equipment was of increased importance due to unavailability of the redundant train or other related equipment. Inspection activities included, but were not limited to, a review of the licensees procedures, verification of equipment alignment, and an observation of material condition, including operating parameters of equipment in-service. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors selected the following equipment trains to assess operability and proper equipment line-up for a total of two inspection samples:
- AFW water train A after return to service from testing; and
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors performed a complete walkdown of equipment for one risk significant mitigating system. The inspectors walked down the system to review mechanical and electrical equipment line-ups, component labeling, component lubrication, component and equipment cooling, hangers and supports, and operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation.
A review of past and outstanding work orders was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that any system equipment alignment problems were being identified and appropriately resolved. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors selected the component cooling water system (CCW) system to assess operability and proper equipment line-up for a total of one inspection sample.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Quarterly Fire Zone Walkdowns
a. Inspection Scope
The inspectors walked down risk significant fire areas to assess fire protection requirements. The inspectors reviewed areas to assess whether the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events, or the potential to impact equipment which could initiate or mitigate a plant transient. The inspection activities included, but were not limited to, the control of transient combustibles and ignition sources, fire detection equipment, manual suppression capabilities, passive suppression capabilities, automatic suppression capabilities, compensatory measures, and barriers to fire propagation. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors selected the following areas for review, for a total of 13 inspection samples:
- Fire Zone PFP-4, Screen House and Tunnel;
- Fire Zone PFP-5, 1A Diesel Generator and Diesel Generator Day Tank Rooms;
- Fire Zone PFP-6, 1B Diesel Generator and Diesel Generator Day Tank Rooms;
- Fire Zone PFP-8, 480-volt Switchgear Bus 1-51 and 1-52 Room;
- Fire Zone PFP-11, Turbine Building Basement;
- Fire Zone PFP-12, Turbine Building Mezzanine - and Related Transformer;
- Fire Zone PFP-14, Turbine Building - Operating Floor;
- Fire Zone PFP-16, Refueling Water Storage Tank and Containment Spray;
- Fire Zone PFP-17, Charging Pump, Boric Acid Pump and Residual Heat Removal Pump Pit;
- Fire Zone PFP-19, Condensate Storage & Reactor Make Up Water Room; and
- Fire Zone PFP-23, Spent Fuel Pool, Waste Handling & Main Steam Relief Valve Area.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors performed an annual review of flood protection barriers and procedures for coping with internal flooding. The inspection focused on determining whether flood mitigation plans and equipment were consistent with design requirements and risk analysis assumptions. The inspection activities included, but were not limited to, a review and/or walkdown to assess design measures, seals, drain systems, contingency equipment condition and availability of temporary equipment and barriers, performance and surveillance tests, procedural adequacy, and compensatory measures. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors selected the following equipment for review, for a total of two inspection samples:
- safeguards alley service water (SW) system; and
- safeguards alley water mitigation and removal with high water level in the related trench.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
Biennial Review of Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the performance of the 1A Component Cooling Heat Exchanger (component ID 135-081) and the RHR pump pit fan coil unit 1A (component ID 155-051). These heat exchangers were chosen for the review based on many factors including, the high risk assessment (RA) worth in the licensees probabilistic risk analysis, the important safety-related mitigating system support functions, and relatively low margin. This review resulted in the completion of two inspection samples. While onsite, the inspectors verified that the inspection, engineering, and maintenance activities were adequate to ensure proper heat transfer. This was done by conducting independent heat transfer capability calculations, reviewing the methods used to inspect the heat exchangers, verifying that the as-found results were appropriately dispositioned, and by personnel interviews. The inspectors also verified, by review of procedures, test results, and interviews, that chemical treatments, ultrasonic tests, and methods used to control biotic fouling, corrosion, and macro-fouling were sufficient to ensure required heat exchanger performance. The inspectors verified that the condition and operation of these heat exchangers were consistent with design assumptions in heat transfer calculations by reviewing related procedures and surveillance. This was performed by reviewing inspect/clean work orders, calculations, and completed surveillance tests. During the inspection, the inspectors walked down the accessible portions of the selected heat exchangers and verified installation configurations complied with design documents and that material condition was adequate.
Also while onsite, the inspectors verified two attributes of the ultimate heat sink (UHS)as required by Inspection Procedure 71111-07B, Section 2.02, Items d.2 and d.6. The inspectors reviewed written documentation of inspections, maintenance, and repairs of below-water portions of underwater UHS structures which ensured UHS structural integrity and sedimentation removal capabilities. The inspectors confirmed that the inspection and maintenance methodologies, including intake crib repairs, were consistent with NRC and industry accepted practices. The inspectors also verified that the licensee had appropriate controls in place to ensure functionality of the UHS during adverse weather conditions including icing or high temperatures.
The inspectors reviewed corrective action documents, concerning heat exchanger or heat sink performance issues to verify that the licensee had an appropriate threshold for identifying issues. The inspectors also evaluated the effectiveness of the corrective actions for identified issues, including the engineering justifications for operability. As part of this inspection, the documents listed in the Attachment were reviewed.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
The inspectors performed a quarterly review of licensed operator requalification training.
The inspectors assessed the licensees effectiveness in evaluating the requalification program, ensuring that licensed individuals operate the facility safely and within the conditions of their license, and evaluated licensed operator mastery of high-risk operator actions. The inspection activities included, but were not limited to, a review of high risk activities, emergency plan performance, incorporation of lessons-learned, clarity and formality of communications, task prioritization, timeliness of actions, alarm response actions, control board operations, procedural adequacy and implementation, supervisory oversight, group dynamics, interpretations of Technical Specifications (TS), simulator fidelity, and licensee critique of performance. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors observed a training crew during an evaluated simulator scenario (description withheld for exam security purposes) for a total of one inspection sample.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed systems the licensee designated as risk significant under the maintenance rule to assess maintenance effectiveness, including maintenance rule activities, work practices, and common cause issues. Inspection activities included, but were not limited to, the licensee's categorization of specific issues, including evaluation of performance criteria, appropriate work practices, identification of common cause errors, extent of condition, and trending of key parameters. Additionally, the inspectors reviewed implementation of the Maintenance Rule (10 CFR 50.65) requirements, including a review of scoping, goal-setting, performance monitoring, short-term and long-term corrective actions, functional failure determinations associated with reviewed corrective action program documents, and current equipment performance status. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors performed a function-oriented review of the following maintenance effectiveness reviews for a total of three inspection samples:
C the instrument air system; C the CCW system; and C the SW system.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed maintenance activities to review RAs and emergent work control. The inspectors verified the performance and adequacy of RAs, management of resultant risk, entry into the appropriate licensee-established risk bands, and the effective planning and control of emergent work activities. The inspection activities included, but were not limited to, a verification that licensee RA procedures were followed and performed appropriately for routine and emergent maintenance, that RAs for the scope of work performed were accurate and complete, that necessary actions were taken to minimize the probability of initiating events, and that activities to ensure that the functionality of mitigating systems and barriers were performed. Reviews also assessed the licensee's evaluation of plant risk, risk management, scheduling, configuration control, and coordination with other scheduled risk significant work for these activities. Additionally, the assessment included an evaluation of external factors, the licensee's control of work activities, and appropriate consideration of baseline and cumulative risk. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors observed maintenance or planning for the following activities or risk significant systems undergoing scheduled or emergent maintenance, for a total of three inspection samples:
- emergent work added during the week of April 14, 2007 including EDG maintenance and heater drain pump maintenance;
- emergent maintenance due to Heater Drain Pump B failure during the week of May 3, 2007; and
- emergent switch yard maintenance during the week of May 29, 2007.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed operability evaluations that affected mitigating systems or barrier integrity to ensure that operability was properly justified and that the component or system remained available. The inspection activities included, but were not limited to, a review of the technical adequacy of the operability evaluations to determine the impact on TSs, the significance of the evaluations to ensure that adequate justifications were documented, and that risk was appropriately assessed. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors reviewed the following operability evaluations for a total of seven inspection samples:
- CAP043450, Diesel Generator A Air Intake Filter Housing to Turbo is Cracked;
- CAP044034, Heat Exchanger Performance Monitoring and Tube Plugging Using Incorrect SW Flow Rates;
- CAP044276, Diesel Generator A Ventilation Measured Flow Readings Lower than Assumed in Calc C10044, Revision 1 and CAP044506, Diesel Generator B Ventilation Measured Flow Readings Lower than Assumed in Calculation C10044, Revision 1;
- CAP044316, Differential Temperatures in WO 07-2513 were Greater than Utilized in OD 151;
- CR013788, Concern on Non-safety-related/safety Related Interface Condensate to Auxiliary Feed Water; and
- CAP044344 Elevated Outdoor Air Temperatures.
b. Findings
.1 Closed Unresolved Item (URI) 05000305/2006003-04: Adequacy of Compensatory
Actions for Potential Turbine Missile Strike of Control Room Ventilation Cooling; and URI 05000305/2006016-01, Adequacy of 10 CFR 50.59 Screening for Procedure Change
Introduction:
A finding having very low safety significance (Green) and an associated Severity Level IV, Cited Violation of 10 CFR 50.59 was identified by the inspectors while reviewing unresolved items URI 05000305/2006003-04, Adequacy of Compensatory Actions for Potential Turbine Missile Strike of Control Room Ventilation Cooling; and URI 05000305/2006016-01, Adequacy of 10 CFR 50.59 Screening for Procedure Change. Specifically, the licensee failed to properly interpret design and licensing basis requirements associated with protection against external events and as a result did not perform a 10 CFR 50.59 evaluation.
Discussion: The inspectors reviewed URI 05000305/2006003-04, "Adequacy of Compensatory Actions for Potential Turbine Missile Strike of Control Room Ventilation Cooling"; and URI 05000305/2006016-01, "Adequacy of 10 CFR 50.59 Screening for Procedure Change." The inspectors determined that both URIs were attributed to a common performance deficiency; the licensee failed to properly interpret TSs and the design and licensing basis associated with system requirements for protection against external events.
Unresolved Item, URI 05000305/2006003-04, discussed a condition where, under certain tornado conditions, compensatory measures to ensure control room cooling was maintained would breach the control room envelope, and render the control room post-accident recirculation system inoperable.
Unresolved Item, URI 05000305/2006016-01, discussed a condition concerning the licensee's conclusion that a 10 CFR 50.59 safety evaluation was not required. The screening was for revising Procedure E-O-05, "Response to Natural Events," to isolate SW to the control room air conditioning system and other structures, systems and components.
In May 2005, during a plant shutdown, the licensee issued CAP027495, Service Water Supplies to CRAC [Control Room Air Conditioning] Units Potentially Impacted by Tornado Missiles, which identified a nonconforming condition associated with the CRAC system. This nonconforming condition involved the vulnerability of the CRAC system SW supply lines to an impact by tornado missiles. The licensee determined that such impact from tornado missiles was credible and could render the CRAC inoperable and could cause the temperature in the control room to exceed equipment qualification limits. This vulnerability had existed since original plant startup.
In July 2005, the licensee started up the plant without compensatory actions in place to ensure that control room temperatures could be maintained below equipment qualification limits if the CRAC was disabled by a tornado missile impact on the SW supply lines to the CRAC.
In May, 2006, shortly before a subsequent plant startup, the NRC inspectors questioned the acceptability of restarting the plant with the CRAC system vulnerable to tornado missile impact. As a result of the inspectors questions, the licensee established compensatory measures in the event the CRAC system SW supply and return piping was rendered inoperable by tornado missiles. The licensee revised plant procedure E-O-05, Response to Natural Events, to establish compensatory measures to require the plant to be shutdown, the control room and relay room doors be opened, and portable non-safety related fans be placed in position to establish airflow from outside the plant structures through the control room. The licensee performed a 10 CFR 50.59 screening on May 15, 2006 for the revised procedure and concluded that the procedure revision and compensatory actions established by the revision were acceptable. The licensee did not discuss the effect this activity would have on control room habitability.
The inspectors noted that opening the control room doors would violate the control room exclusion zone (CREZ) envelope and would render the control room post accident recirculation system ineffective. The CRAC, the CREZ, and the control room post accident recirculation system are specifically required by the Kewaunee Power Station USAR, Appendix B, to be able to withstand a tornado. The inspectors were concerned that violating the CREZ boundary would render the control room and its inhabitants vulnerable to exposure to smoke, toxic gases, and radioactive releases which may be present in the environment external to the plant following a tornado strike.
The licensee stated that their basis for not performing a 10 CFR 50.59 evaluation was that the procedural changes to E-O-05 required the reactor to be shut down prior to implementation of the compensatory measures, a condition where maintenance of the CREZ boundary and utilization of control room recirculation was not required by plant TSs. As such, the licensee concluded that it would have been acceptable to implement the compensatory measures without prior NRC approval.
The inspectors noted that the CRAC, the CREZ and the control room post-accident recirculation system are specifically required by the plant licensing basis to be able to withstand a tornado strike. Additionally, there is no provision in the plant licensing basis which would allow these systems to be rendered inoperable by a tornado strike, nor are there any provisions which would allow the licensee to render the systems inoperable following a tornado strike. The inspectors concluded that a failure to perform a proper 50.59 evaluation for the compensatory measures established in procedure E-O-05 was a performance deficiency because potential events associated with a tornado including, fire, toxic gas, a radiological hazards were not assessed.
During the fall 2006 refueling outage, the licensee installed tornado missile shielding around the CRAC SW supply and return lines to ensure that the CRAC would not be disabled by a tornado.
Analysis:
The inspectors determined that the licensees failure to perform a 10 CFR 50.59 evaluation for procedure E-O-05 was a performance deficiency warranting further review. Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Significance Determination Process. In this case, the licensee failed to perform a safety evaluation in accordance with 10 CFR 50.59 for changes made to Procedure E-O-05 concerning compensatory measures which would implement design changes following a tornado strike on the plant. These procedural and design changes would violate the CREZ boundary, require that outside air be forced into the control room using non-safety related fans and render the recirculation function of control room ventilation system unable to perform its design function.
This finding was determined to be more than minor because the inspectors determined that the procedure change would have ultimately required NRC approval. The procedure changes, in the form of compensatory operator actions, adversely impacted the operation of control room recirculation system following a tornado. The inspectors completed a significance determination of this finding using IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations."
The inspectors determined that the finding could be evaluated using the Phase 1 Severe Weather Screening Criteria questions. Since the loss of the control room recirculation system would not result in an initiating event or degrade two or more trains of a multi-train safety system, the issue screens as Green.
The inspectors also determined that the finding has a cross-cutting aspect in the area of problem identification and resolution because the licensee had similar problems previously that, if effectively evaluated and resolved, could have prevented this issue.
Specifically, a Non-cited, Severity Level IV, Violation (NCV 05000305/2005002-06) was issued previously, which also indicated a 10 CFR 50.59 evaluation should have been performed for a temporary procedure change that proposed compensatory actions to address degraded or nonconforming conditions. More specifically, the non-cited violation was related to changes to Procedure E-O-05 that established compensatory measures in the event of a tornado watch or warning. The violation concluded that the introduction of procedure changes which introduced adverse effects was a performance deficiency. The inspectors reviewed CAP025487, which implemented corrective actions for NCV 05000305/2005002-06, and found that it narrowly focused the corrective actions to the procedural step performed incorrectly, and that the corrective actions did not broadly review or correct the implementation and training deficiencies that contributed to the procedural noncompliance. (P.1(c))
Enforcement:
The inspectors concluded that the licensee failed to perform a 10 CFR 50.59 evaluation for compensatory measures associated with a procedure change to Procedure E-O-05. The inspectors concluded that the 10 CFR 50.59 screening, No. 06-35-00, performed by the licensee did not cover all aspects of a tornado strike, including potential fire, toxic gas, or radiological hazards; nor did the screening assess the impact of these hazards on control room habitability when compensatory measures were adopted that disabled the system. The licensee made an incorrect assumption because they incorrectly interpreted plant TSs to allow the disabling of important safety systems, which might be required to protect control room personnel or maintain plant safety following a tornado strike.
The inspectors reviewed this issue for discretion as an old design issue and found that the licencee failed to implement immediate compensatory measures when the condition was first identified in 2005, therefore the issue did not meet the requirements for discretion per Section VII.B.3 of the NRC Enforcement Policy for an Old Design Issue.
Because discretion and an NCV were not applicable, and because the inspectors concluded that the issue was attributable to the same performance deficiency associated with both URIs above, the design implications were adequately covered by this violation.
Title 10 CFR 50.59(d)(1) requires, in part, that the licensee maintain records of changes in the facility, of changes in procedures, and of tests and experiments. These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment. Contrary to the above, the licensee issued an operating procedure change that introduced adverse consequences during an tornado and failed to perform an adequate safety evaluation in accordance with 10 CFR 50.59.
The results of this violation were determined to be of very low safety significance (Green). However, this violation of the requirements in 10 CFR 50.59 was classified as a Severity Level IV Violation. Although the licensee has entered aspects of this issue in the corrective action program (primarily to document and answer inspection related questions) the licensee disagrees with this violation and therefor corrective actions have not been proposed to address the issue; as such, this violation is being treated as a Cited Severity Level IV Violation consistent with Section VI.A of the NRC Enforcement Policy (VIO 05000305/2007003-01).
.2 Equipment and References for Response to an Earthquake Potentially Inadequate
Introduction:
The inspectors identified an URI associated with the possible lack of USAR information related to the seismic response of the CRAC system, the adequacy and qualification of compensatory equipment for a seismic event, and the potential issues with supporting documentation for the licensees Generic Letter (GL) 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment In Operating Reactors (USI A-46) response.
Discussion: While reviewing URI 05000305/2006016-01 and URI 05000305/2006003-04, the inspectors noted that the licensee referenced Regulatory Guide 1.117, Tornado Design Classification, and Generic Letter GL 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment In Operating Reactors (USI A-46). Using these references, including the licensee response and associated NRC safety evaluation for GL 87-02, the licensee concluded that a 10 CFR 50.59 evaluation was not required or procedure changes to E-O-05. Notably the licensee concluded that in their response to USI A-46 that opening the control room doors was a method used to compensate for any cooling issues that might arise as a result of an earthquake.
The inspectors noted that equipment, procedures, and calculations to support the opening of the control room boundary were only established as a result of deficiencies associated with the tornado missile vulnerability to the SW supply to the CRAC system.
The inspectors were concerned that the equipment, procedures, and calculations may have been prior credited in the USI A-46 response and would have been presumed available prior to the CRAC issue. Additionally, the licensee removed the related equipment and stored it in a non-seismically controlled building following completion of the modifications to protect the CRAC SW supply piping from tornado missiles. The inspectors noted that the licensee had multiple opportunities to recognize the relationship between the compensatory equipment and seismic requirements as stated in USI A-46, and therefore considered their failure to recognize these requirements a performance deficiency.
Because the licensee referenced their USI A-46 seismic response as supporting this conclusion, the inspectors reviewed the related documentation and were unable to determine whether appropriate regulatory processes, such as 50.59, were used to establish compensatory measures that were credited in the USI A-46 response and subsequent safety evaluation report. Also, the inspectors noted that the compensatory measures the licensee credited for this issue might constitute a permanent modification to the design and if so, that the compensatory equipment should be seismically available and subject to the requirements of 10 CFR 50, Appendix B. The inspectors also noted that the USAR references supporting this safety evaluation report may not have sufficiently described the earthquake response and compensatory measures. These observations caused the inspectors to lose confidence that the permanently established compensatory measures and equipment was appropriate qualified, tested, and maintained for responding to a seismic event, and that the appropriate regulatory processes, such as 10 CFR 50.59 and 10 CFR 50 Appendix B, were used. Therefore, the inspectors considered the possible lack of information in the USAR related to the seismic response of the CRAC, the adequacy and qualification of compensatory equipment for a seismic event, and the potential issues with supporting documentation for the licensees A-46 response unresolved pending further review.
.3 Potentially Inappropriate Safety/Nonsafety-Related Interface for Condensate Storage
Tank System and Safety-Related Auxiliary Feedwater Pumps
Introduction:
The inspectors identified a URI associated with a potentially inappropriate safety/nonsafety-related interface for the condensate storage tank system and the safety related AFW pumps.
Description:
While performing followup inspection activities associated with URI 05000305/2006003-03, Potentially Inappropriate Safety/Nonsafety-Related Interface for Bearing Cooling and Flushing Water to the Safety-Related Services Water Pumps, the inspectors noted that there were other systems in the plant where the interface between nonsafety-related and safety-related systems were potentially inappropriate.
Specifically, the inspectors noted that the condensate storage tank was a nonsafety-related system which interfaced directly with the safety-related AFW System and questioned various design aspects related to the interface. At the end of the inspection period the licensee had not responded to the inspectors questions about the safety/nonsafety-related interface for the condensate storage tank system and the safety-related AFW pumps. Therefore this issue was consider unresolved pending the review of the licensees investigation and resolution of the inspectors design interface questions (URI 05000305/2007003-03).
1R17 Permanent Plant Modifications
a. Inspection Scope
The inspectors review of permanent plant modifications focused on verification that the design bases, licensing basis, and performance capability of related structures, systems or components were not degraded by the installation of the modification.
The inspectors also verified that the modifications did not place the plant in an unsafe configuration. The inspection activities included, but were not limited to, a review of the design adequacy of the modification by performing a review, or partial review, of the modifications impact on plant electrical requirements, material requirements and replacement components, response time, control signals, equipment protection, operation, failure modes, and other related process requirements.
As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors selected a permanent plant modification to insulate CCW system piping for review, for a total of one inspection sample.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors verified that the post-maintenance test procedures and activities were adequate to ensure system operability and functional capability. Activities were selected based upon the structure, system, or component's ability to impact risk. The inspection activities included, but were not limited to, witnessing or reviewing the integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use and compliance, control of temporary modifications or jumpers required for test performance, documentation of test data, system restoration, and evaluation of test data. Also, the inspectors verified that maintenance and post-maintenance testing activities adequately ensured that the equipment met the licensing basis, TSs, and USAR design requirements. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors reviewed post-maintenance activities associated with the following components for a total of eight inspection samples:
- EDG air box repair;
- SW CUNO filter repair;
- leak repair to instrument air compressor RT-AS-01;
- maintenance on RHR-400B, residual heat removal to containment spray supply valve;
- routine maintenance to charging pump 1-B on April 17, 2007;
- repair of supply breaker to shield building ventilation Train B;
- repair of lifting relief valves to G instrument air compressor; and
- maintenance on charging pump 1-B on June 12, 2007.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed surveillance testing activities to assess operational readiness and to ensure that risk-significant structures, systems, and components were capable of performing their intended safety function. Activities were selected based upon risk significance and the potential risk impact from an unidentified deficiency or performance degradation that a system, structure, or component could impose on the unit if the condition was left unresolved. The inspection activities included, but were not limited to, a review for preconditioning, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use, control of temporary modifications or jumpers required for test performance, documentation of test data, TS applicability, impact of testing relative to performance indicator reporting, and evaluation of test data. As part of this inspection, the documents listed in the were reviewed.
The inspectors selected the following surveillance testing activities for review for a total of fourteen inspection samples:
- EDG B safety injection test following repairs;
- EDG B fast start test;
- technical support center diesel generator start and load test;
- safety injection pump A pump and valve test (Containment Isolation Valve);
- EDG A airflow and temperature test;
- turbine first stage pressure instrument check;
- EDG B airflow and temperature test;
- miscellaneous valve timing;
- special ventilation zone test;
- CCW train B pump and valve test;
- train A miscellaneous valve timing test (Inservice Testing);
- EDG A availability test; and
- RHR train B pump and valve test.
b. Findings
Introduction:
A finding having very low safety significance (Green) and an associated non-Cited Violation of 10 CFR 50, Appendix B, Criterion V, Instructions , Procedures, and Drawings, was identified by the inspectors while reviewing surveillance testing procedures for the auxiliary building special ventilation zone (Zone SV). Specifically, the licensee procedure for tracking the amount of in-leakage into the Zone SV did not have adequate criteria to capture degraded conditions, nor ensure that the acceptance criteria reflected the design requirements of the system.
Discussion: Between January and May 2007, during the component design basis inspection and during the daily review of newly created condition reports (CRs), the inspectors identified a number of CRs related to Zone SV. As a result of this observation, the inspectors reviewed the last performance of SP-14-0117A, Auxiliary Building Special Ventilation Test Train A, Revision A, completed during the Fall 2006, refueling outage. The inspectors reviewed the TS requirements and design requirements as stated in the USAR, to ensure that the requirements were adequately translated into the surveillance test.
The USAR indicated that the zone SV system was designed to maintain specified flow rates through open doors and was designed to remain operable with up to 200 square-feet of openings. The inspectors could not determine how the related test procedure ensured that these requirements were met. Additionally, during the Component Design Bases Inspection, the inspectors identified CRs which indicated roof leakage penetrating the Zone SV boundary, and the licensee identified that a floor drain provided communication across the zone boundary.
The licensee indicated that procedure FPP-08-09, Barrier Control, was the method used to track and control in-leakage. The inspectors reviewed the items being tracked and found that the procedure tracked items through the barrier impairment permitting process, yet did not capture other issues including the breach in the boundary through the leaking roof. Because numerous CRs existed related to Zone SV issues, including multiple roof leaks, penetration leakage, and improper storage of equipment, the inspectors concluded that the licensee had multiple opportunities to recognize the impact of barrier breaches on the design requirements of Zone SV and failed to correct the problems.
Additionally, because the licensee were not sure how the design requirements were translated into procedures, the licensee issued CAP043818, Zone SV USAR Allowed Leakage Area May Be Non-conservative. As a result, a review of the design requirements was performed and initial findings indicated that the non-conservatism may be as large as 100 square-feet, approximately 50 percent of the prior presumed allowable of 200 square-feet. As a result of these observations, the licensee modified procedure FPP-08-09 to better track barrier breaches and conservatively limit the total amount of allowed breaches until a full review could be performed.
Analysis:
The inspectors determined that the licensees failure to recognize the impact of degraded conditions, that were effectively barrier breaches, on the design requirements of Zone SV was a performance deficiency warranting further review. This issue was determined to be more than minor because, if left uncorrected, the failure to evaluate barrier breaches that did not have barrier permits could become a more significant safety concern. Specifically, if left unmonitored, the breaches without barrier permits could potentially exceed the allowable design limits.
The inspectors evaluated the finding using IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. The inspectors answered yes to Question 1 in the in the Significance Determination Process Phase 1 Screening Worksheet in the Containment Barrier Cornerstone column; therefore, this finding is of very low safety significance (Green).
The inspectors also determined that the finding affected the cross-cutting area of problem identification and resolution because the licensee failed to properly evaluate multiple CRs for operability and extent of condition. Specifically, the CRs associated with Zone SV roof leakage, if evaluated for extent of condition and impact on the safety related function of equipment in the zone, should have resulted in the licensee identifying that barrier breaches were not properly tracked or quantified. Additionally, an extent of condition should have revealed that the design parameters as stated in the USAR were non-conservative. (P1(c))
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances, and that include appropriate acceptance criteria. Contrary to this requirement, Procedure FPP-08-09, Barrier Control, failed to contain requirements that appropriately tracked all barrier breaches or acceptance criteria that appropriately represented design requirements.
Specifically, FPP-08-09, did not track degraded and non-conforming conditions (breaches) without barrier permits, and contained acceptance criteria that was found to be non-conservative.
The licensee entered this item into its corrective action program as CAP043818.
Corrective actions to date included revisions to procedure FPP-08-09, to track barrier breaches that result from degraded conditions and provide conservative acceptance criteria. Planned corrective actions include increasing the priority of the creation of a design basis document for Zone SV ,and revising design calculations for Zone SV to ascertain the exact design basis and requirements of the system. Because this violation was of very low safety significance and it was entered into the licensees corrective action program, this violation is being treated as a NCV consistent with Section VI.A of the NRC enforcement policy (NCV 05000305/2007003-04).
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 Kewaunee Power Station USAR to identify applicable radiation monitors associated with measuring transient high and very high radiation areas (HRAs) including those used in remote emergency assessment. The inspectors identified the types of portable radiation detection instrumentation used for job coverage of HRA 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. Contamination monitors, whole body counters and those radiation detection instruments utilized for the release of personnel and equipment from the Radiologically Controlled Area (RCA) 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 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 RP 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 assess whether they were used adequately.
Licensee personnel demonstrated the methods for performing source checks of portable survey instruments.
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 HRAs, 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 TSs, as applicable, and were consistent with industry practices and regulatory guidance.
The inspectors assessed what actions were taken when, during calibration or source checks, an instrument was found significantly out of calibration or exceeded as-found acceptance criteria. The inspectors evaluated the licensees actions including the 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 sites 10 CFR Part 61 source term (radionuclide mix) to evaluate 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 corrective action program (CAP) documents and any special reports that involved personnel contamination monitor alarms due to personnel internal exposures to assess whether identified problems were entered into the corrective action program for resolution. Licensee self-assessments, field observations and CAP records were also reviewed to verify that problems with radiological instrumentation or self-contained breathing apparatus were identified, characterized, prioritized, and resolved effectively using the corrective action program.
The inspectors reviewed corrective action program 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 RP 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 corrective actions.
The inspectors assessed whether the licensees self-assessment, audit and/or field observation activities completed for the two 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 determined whether calibrations for those instruments recently used and for those designated for use were current and had not lapsed prior to use. The inspectors also discussed instrument calibration methods and source response check practices with RP 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 assess whether 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 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 assess whether 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 evaluate whether 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 evaluate 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 assess whether 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.
2PS3 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program (71122.03)
.1 Inspection Planning
a. Inspection Scope
The inspectors reviewed the 2005 and 2006 Annual Radiological Environmental Operating Reports, and licensee assessment results to evaluate whether the REMP was implemented as required by the Radiological Environmental Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM). The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring and commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, interlaboratory comparison program, and data analysis. The inspectors reviewed the ODCM to identify environmental monitoring stations and evaluated licensee self-assessments, audits, licensee event reports, and interlaboratory comparison program results. The inspectors reviewed the USAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation. The inspectors also reviewed the scope of the licensees audit program to determine if it met the requirements of 10 CFR 20.1101(c). This review represented one sample.
b. Findings
No findings of significance were identified.
.2 Onsite Inspection
a. Inspection Scope
The inspectors walked down selected air sampling stations (50 percent) and approximately 20 percent of the thermoluminescent dosimeter monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition.
The inspectors observed the collection and preparation of environmental air samples.
Other samples (e.g. milk, water, vegetation samples) were not collected during the inspection week. The environmental sampling program was evaluated to determine if it was representative of the release pathways as specified in the ODCM and that sampling techniques were performed in accordance with station procedures.
The inspectors evaluated the condition of the meteorological instruments using observations and record reviews, and assessed whether the equipment was operable, calibrated, and maintained in accordance with guidance contained in the USAR, NRC Safety Guide 23, and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments, including computer interfaces and data loggers, that measure and record wind speed, wind direction, delta temperature, and atmospheric stability measurements were available on the licensees computer system and whether this information was available in the control room.
The inspectors reviewed each event documented in the Radiological Environmental Operating Report that involved missed samples, inoperable samplers, lost thermoluminescent dosimeters, or anomalous measurements for the cause and corrective actions.
The inspectors reviewed the ODCM for significant changes that resulted from land use census modifications, or sampling station changes made since the last inspection.
This included a review of technical justifications for changed sampling locations. The inspectors assessed whether the licensee performed reviews required to ensure that the changes did not affect their ability to monitor the impacts of radioactive effluent releases on the environment.
The inspectors reviewed the calibration and maintenance records for five air samplers to evaluate operating parameters. The inspectors reviewed results of the vendors interlaboratory comparison program and quality assurance programs to assess the adequacy of environmental sample analyses performed by the licensee.
The inspectors reviewed quality assurance audit results of the REMP to determine whether the licensee met the TS/ODCM requirements.
These reviews represent six samples.
b. Findings
No findings of significance were identified.
.3 Unrestricted Release of Material From the Radiologically Restricted Area
a. Inspection Scope
The inspectors observed the access control location where the licensee monitored potentially contaminated material leaving the radiologically controlled area and inspected the methods used for control, survey, and release of material from this area.
The inspectors observed the performance of personnel surveying and releasing material for unrestricted use to verify that the work was performed in accordance with plant procedures.
The inspectors evaluated whether the radiation monitoring instrumentation was appropriate for the radiation types present and was calibrated with appropriate radiation sources that represented the expected isotopic mix. The inspectors reviewed the licensees criteria for the survey and release of potentially contaminated material and verified that there was guidance on how to respond to an alarm indicating the presence of licensed radioactive material. The inspectors evaluated the licensees equipment to determine if radiation detection sensitivities were consistent with the NRC guidance contained in IE Circular 81-07 and IE Information Notice 85-92 for surface contamination, and Health Physics Position (HPPOS)-221 for volumetrically contaminated material.
The inspectors reviewed the licensees procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters such as counting times and background radiation levels. The inspectors assessed whether the licensee had established a release limit by altering the instruments typical sensitivity through such methods as raising the energy discriminator level or locating the instrument in a high radiation background area.
These reviews represent two samples.
b. Findings
No findings of significance were identified.
.4 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed the licensees self-assessments, audits, CRs, and special reports related to the radiological environmental monitoring program since the last REMP inspection to determine if identified problems were entered into the corrective action program for resolution. The inspectors also assessed whether the licensee's self-assessment program was capable of identifying and addressing repetitive deficiencies or significant individual deficiencies that were identified by the problem identification and resolution process.
The inspectors also reviewed corrective action documents related to the REMP that affected environmental sampling and analysis, and meteorological monitoring instrumentation. Staff members were interviewed and documents were reviewed to determine if the following activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk:
- initial problem identification, characterization, and tracking;
- disposition of operability/reportability issues;
- evaluation of safety significance/risk and priority for resolution;
- identification of repetitive problems;
- identification of contributing causes;
- identification and implementation of effective corrective actions;
- resolution of NCVs tracked in the corrective action system; and
- implementation/consideration of risk significant operational experience feedback.
This review represented one sample.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
Cornerstone: Initiating Events
Reactor Safety Strategic Area
a. Inspection Scope
The inspectors used Nuclear Energy Institute NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, to assess the accuracy of the PI data.
The inspectors review included, but was not limited to, conditions and data from logs, licensee event reports, corrective action program documents, and calculations for each PI specified. As part of this inspection, the documents listed in the Attachment were reviewed.
The Unplanned Power Changes per 7000 Critical Hours PI for the period of March 2006 through March 2007 was reviewed for a total of one inspection sample.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As part of the routine inspections documented in this inspection report, the inspectors verified that the licensee entered the problems identified during the inspection into their corrective action program. Additionally, the inspectors verified that the licensee was identifying issues at an appropriate threshold and entering them in the program, and verified that problems included in the program were properly addressed for resolution.
Attributes reviewed included: problems were completely and accurately identified; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and classification, prioritization, and focus were commensurate with safety and sufficient to prevent recurrence of the issue.
b. Findings
No findings of significance were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
To assist with the identification of repetitive equipment failures and specific human performance issues for follow-up by the inspectors, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by reviewing daily CAP summary reports and attending corrective action review board meetings.
b. Findings
No findings of significance were identified.
.3 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees corrective action program to identify trends that might indicate the existence of a more significant safety issue. The review was focused on trending program deficiencies, which considered licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the period of January through June 2007, with some examples extending beyond those dates when the scope of a trend warranted.
The inspectors reviewed adverse trend CAP report items associated with various problems that occurred during the period along with CAPs closed to trending. The review included issues that were documented outside the normal corrective action program, departmental problem/challenges lists, and self-assessment reports. The inspectors compared and contrasted the licensees trends with those discussed in the licensees trending documents. Corrective actions associated with a sample of the issues identified in the licensees trend report or through interviews with licensee management, were reviewed for adequacy. The inspectors focused on those corrective actions pertaining to the trending program.
The inspectors also evaluated the report against the requirements of the licensees corrective action program as specified in the associated administrative procedure; 10 CFR Part 50; Appendix B. Documents reviewed during this inspection are listed in the Attachment to this report.
b. Assessment and Observation The inspectors requested a list of all CAPs since January 2007 that included the keyword trend. Approximately 150 CAPs were reviewed and almost all were categorized as close to trend, with one identified adverse trend. The inspectors performed an independent search for adverse trends and confirmed the information given. CAP041495, CAPs Needing Trend Coding, described that there was a backlog of over 5000 CAPs that were in the Trend Review Pending state. After discussions with the Assessments CAP Liaison, the inspectors determined that the licensee did not have a plan or path forward to work this backlog down, nor did the licensee have the resources needed to accomplish the work. In reviewing the Kewaunee 2006 NRC Quarterly Inspection Reports, this issue was potentially related to the Hot Button issue described in Inspection Report 2006-003 and 2006-005. The licensee has recently transitioned from Hot Buttons to Focus on Four categories for categorizing and trending CAPs due to inadequacies in the process. The inspectors concluded that the large backlog of CAPs needing trending related to the previous Hot Button inadequacies described in the aforementioned inspection reports remained an area for improvement in trending CAPs.
No findings of significance were identified.
.4 Selected Issue Follow-Up: Station Main Fire Pump Degradation
a. Inspection Scope
The inspectors performed a review of the licensees CAPs that were associated with a trend. During this review, the inspectors noted that CAP042087, Fire Pump refurbishment/replacement, described a declining trend in both station main fire pumps performance. The inspectors reviewed the adequacy of the corrective actions for CAP042087.
b. Assessment and Observation The inspectors evaluated the licensees corrective actions, which included work orders and work requests. The inspectors also interviewed the System Engineer, who described the trending performed for both station main fire pumps.
No findings of significance were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion
Personnel Performance During Non-Routine Plant Evolutions and Events
a. Inspection Scope
The inspectors reviewed personnel performance to unplanned non-routine evolutions to review operator performance and the potential for operator contribution to the evolution.
The inspectors observed or reviewed records of operator performance during the evolution. Reviews included, but were not limited to, operator logs, pre-job briefings, instrument recorder data, and procedures. As part of this inspection, the documents listed in the Attachment were reviewed.
The inspectors evaluated the following evolutions for a total of three inspection samples:
- EDG A and B declared inoperable due to high outside air temperature;
- EDG jacket water heat exchanger design basis performance analysis is not bounding; and
- feedwater regulating valve oscillating causing fluctuations in thermal reactor power.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Ms. L. Hartz and other members of licensee management on July 11, 2007. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
Interim exits were conducted for:
- the results of the heat sink biennial inspection were presented to the Plant Manager, Mr. M. Crist, and other members of licensee management and staff at the conclusion of the inspection on April 20, 2007;
- the radiation monitoring instrumentation and protective equipment program under the occupational radiation safety cornerstone with Mr. M. Crist on June 29, 2007. A technical debrief was conducted with Mr. M. Crist on May 11, 2007; and
- the radiological environmental monitoring program under the public radiation safety cornerstones inspection with Mr. M. Crist on June 29, 2007.
4OA7 Licensee-Identified Violations
None.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- L. Armstrong, Site Engineering Director
- T. Breene, Nuclear Licensing Manager
- M. Crist, Plant Manager
- M. Hale, Radiation Protection and Chemistry Manager
- L. Hartz, Site Vice-President
- W. Henry, Maintenance Manager
- J. Ruttar, Operations Manager
- S. Wood, Emergency Preparedness Manager
Nuclear Regulatory Commission
- J. Cameron, Chief, Division of Reactor Projects, Branch-5
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000305/2007003-01 VIO Failure to Perform a 10 CFR 50.59 Evaluation for Compensatory Measures Associated with a Procedure Change (Section 1R15.b.1)
- 05000305/2007003-02 URI Inadequate Equipment and References for Response to an Earthquake (Section 1R15.b.2)
- 05000305/2007003-03 URI Inappropriate Safety/Nonsafety-Related Interface for Condensate Storage Tank System and Safety-Related Auxiliary Feedwater Pumps (Section 1R15.b.3)
- 05000305/2007003-04 NCV Inadequate Procedure for Surveillance Testing of Auxiliary Building Special Ventilation Zone (Section 1R22.b)
Closed
- 05000305/2006003-04 URI Adequacy of Compensatory Actions for Potential Turbine Missile Strike of Control Room Ventilation Cooling (Section 1R15.b.1)
- 05000305/2006016-01 URI Adequacy of 10 CFR 50.59 Screening for Procedure Change (Section 1R15.b.1)
- 05000305/2007003-04 NCV Inadequate Procedure for Surveillance Testing of Auxiliary Building Special Ventilation Zone (Section 1R22.b)
Attachment