IR 05000282/2014002
| ML14127A025 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/05/2014 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
| To: | Davison K Northern States Power Co |
| References | |
| IR-14-002 | |
| Download: ML14127A025 (45) | |
Text
UNITED STATES May 5, 2014
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT 05000282/2014002; 05000306/2014002
Dear Mr. Davison:
On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Prairie Island Nuclear Generating Plant, Units 1 and 2. The enclosed report documents the results of this inspection, which were discussed on April 3, 2014, with you and other members of your staff.
One NRC-identified finding of very low safety significance (Green) was identified during this inspection. This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) in accordance with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the subject or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy 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 Resident Inspector Office at the Prairie Island Nuclear Generating Plant.
If you disagree with the cross-cutting aspect assignment to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Prairie Island Nuclear Generating Plant. Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross-cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Prairie Island Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and 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 Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Kenneth Riemer Branch 2 Division of Reactor Projects Docket Nos. 50-282; 50-306;72-010 License Nos. DPR-42; DPR-60; SNM-2506
Enclosure:
IR 05000282/2014002; 05000306/2014002 w/Attachment: Supplemental Information
REGION III==
Docket Nos: 50-282; 50-306;72-010 License Nos: DPR-42; DPR-60; SNM-2506 Report No: 05000282/2014002; 05000306/2014002 Licensee: Northern States Power Company, Minnesota Facility: Prairie Island Nuclear Generating Plant, Units 1 and 2 Location: Welch, MN Dates: January 1 through March 31, 2014 Inspectors: K. Stoedter, Senior Resident Inspector P. LaFlamme, Resident Inspector E. Sanchez-Santiago, Acting Resident Inspector S. Bell, Health Physics Inspector J. Bozga, Engineering Inspector L. Haeg, Senior Resident Inspector - Duane Arnold M. Phalen, Health Physics Inspector Approved by: K. Riemer, Chief Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000282/2014002; 05000306/2014002; 01/01/2014 - 03/31/2014;
Prairie Island Nuclear Generating Plant, Units 1 and 2; Operability Evaluations.
This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.
The finding was considered a non-cited violation (NCV) of NRC regulations. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, or Red) and determined using IMC 0609, Significance Determination Process (SDP) dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310; Components Within the Cross-Cutting Areas dated January 1, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a finding of very low safety significance and an non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, on February 13, 2014, due to the failure to construct scaffolds as required by Procedure D80, Scaffolding, Ladders and Cable Trays Platforms. During routine plant walk downs, the inspectors identified multiple examples where scaffolds were erected within the two inch minimum clearance requirement without proper justification. Corrective actions for this issue included walking down all scaffolds erected onsite and removing those that failed to comply with Procedure D80, briefing maintenance, operations and engineering staff on scaffolding clearance requirements, and a future revision to Procedure D80 to better clarify the minimum clearance requirements.
The inspectors determined that this issue was more than minor because it impacted the protection against external factors attribute of the Mitigating Systems cornerstone. In addition, the finding impacted the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, multiple scaffolds were erected in contact with safety-related equipment, or within the minimum clearance distance which could have challenged the availability, reliability or capability of safety-related systems during a seismic event. This issue was of very low safety significance because each question provided in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, was answered No. The inspectors concluded that this finding was cross-cutting in the Human Performance, Conservative Bias area because workers did not utilize prudent decision making practices while erecting scaffolding near safety-related equipment (H.14). (Section 1R15)
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at full power. On March 31, 2014, operations personnel lowered reactor power to 98 percent to perform maintenance on the 11B and 13B feedwater heater control systems. Reactor power remained at 98 percent at the conclusion of the inspection period. Other small power reductions were required during the inspection period to allow for routine testing of plant equipment.
Unit 2 began the inspection period in Mode 3 as part of Refueling Outage 2R28. At 1538 on January 1, 2014, Unit 2 entered Mode 2 and began reactor startup activities. Mode 1 was entered at 1118 on January 2, 2014; full power was achieved on January 13, 2014. Unit 2 operated at full power until March 14, 2014, when power was reduced to 30 percent to allow the repair of a component cooling water leak inside of containment. Following the repairs, Unit 2 returned to full power and remained there through the duration of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and Emergency Preparedness
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Condition - Extreme Cold Conditions
a. Inspection Scope
Since extreme cold conditions were forecast in the vicinity of the facility for January 23 through January 28, 2014, the inspectors reviewed the licensees overall preparations/protection for the expected weather conditions. On the dates listed above, the inspectors walked down heating and ventilation systems in the plant screen house, the turbine building, the auxiliary building and the D5/D6 building to ensure the buildings were sufficiently warm to support the continued operability of safety-related equipment.
The inspectors observed insulation, heat trace circuits, heater operation, and weatherized enclosures to ensure operability of affected systems. During this time, the licensee also operated under a grid condition yellow condition. Under this condition, the licensee suspended testing and maintenance activities that could potentially impact continued plant operation and the electrical grid. The inspectors reviewed licensee procedures and discussed potential compensatory measures with control room personnel. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- 12 Diesel Driven Cooling Water Pump and associated piping;
- 22 Residual Heat Removal Pump and associated piping;
- 22 Shield Building Ventilation System; and
- 121 Control Room Chilled Water Pump and associated piping.
The inspectors selected these systems based on their risk-significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Safety Analysis Report (USAR), Technical Specification (TS)requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions.
The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.
The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies.
The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
On February 26, 2014, the inspectors performed a complete system alignment inspection of the safeguards chilled water system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the to this report.
These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- Fire Areas 4 and 85 - Unit 1 and Unit 2 auxiliary building and fuel handling areas;
- Fire Area 58 - Unit 1 auxiliary building (695 elevation);
- Fire Zone 19 - Spent Fuel Pool Cooling Heat Exchanger and Pump Area; and
- Fire Areas 25 and 26 - D1 and D2 Emergency Diesel Generator Rooms.
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the licensees Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the licensees ability to respond to a security event. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.
These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding
.1 Underground Vaults
a. Inspection Scope
The inspectors selected underground bunkers/manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors determined that the cables were not submerged, that splices were intact, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as a sump pump, the device was operable and level alarm circuits were set appropriately to ensure that the cables would not be submerged. In those areas without dewatering devices, the inspectors verified that drainage of the area was available, or that the cables were qualified for submergence conditions. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following underground bunkers/manholes subject to flooding:
- 13.8KV Cable Vault between Switch Yard and Substation.
Documents reviewed are listed in the Attachment to this report. This inspection constituted one underground vaults sample as defined in IP 71111.06-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On February 4, 2014, the inspectors observed a crew of licensed operators in the simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
a. Inspection Scope
In early January, the inspectors observed Unit 2 power ascension activities following the completion of Refueling Outage (RFO) 2R28. This was a multi-day activity that required heightened awareness in the control room or was related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated performance issues involving the following risk-significant systems:
- Containment Ventilation and
- Radiation Monitoring.
The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- Planned maintenance on one of two Unit 1 offsite electrical sources, fire protection valves, the D6 emergency diesel generator (EDG) high temperature coolant pump, the 21 residual heat removal (RHR) system and the 121 and 122 recycle gates;
- Emergent maintenance on the 12 shield building ventilation system (SBSVS) and planned maintenance on the 12 cooling water strainer, the A cooling water header, the D1 EDG and the 11 RHR pump;
- Emergent maintenance on the 21 SBSVS and planned maintenance on the 12 electrohydraulic control (EHC) system unloader valve, the D2 EDG and fire protection piping;
- Planned maintenance on the 12 EHC pump and the 121 control room chiller; and
- Planned maintenance on the 22 diesel driven cooling water pump and the 122 control room chiller.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Documents reviewed are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- 22 Control Rod Drive Mechanism Cooling Water Isolation Valve (CV-39417)failure to stroke closed;
- CAP 1419465 - Scaffolding in Contact with 121 Control Room Chiller;
- CAP 1422058 - Discovered Unit 1 and Unit 2 Component Cooling Water Surge Tank Levels Decreasing; and
- Operability Recommendation 1404840-01 - Extension in Time Required to Replace Electrical Cables 16408-1 and 16408-2 from Transformer CT-11 to Bus 16.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and USAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
This operability inspection constituted five samples as defined in IP 71111.15-05.
b. Findings
Introduction:
The inspectors identified a finding of very low safety significance (Green)and an NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, on February 13, 2014, due to the licensees failure to install scaffolds as required by Procedure D80, Scaffolding, Ladders and Cable Trays Platforms.
Specifically, the inspectors identified multiple instances where erected scaffolds were installed within the two inch minimum clearance without appropriate justification.
Description:
While performing a routine tour of the screen house on February 13, 2014, the inspectors identified a scaffold in direct contact with an electrical power conduit associated with the 22 cooling water system strainer. The inspectors noted that Procedure D80, Scaffold, Ladders and Cable Tray Platforms, Step 3.1.3 stated, in part, that a minimum of 2 inches of clearance must be maintained between the scaffold and safety-related equipment. The minimum clearance could be reduced to 1 inch as long as engineering evaluated the condition and approved the configuration. No contact was allowed between scaffolding and safety-related equipment.
The inspectors communicated their observation to the licensee. The licensee entered the issue into the corrective action program as CAP 1418846. In response to the inspectors observation, the licensee performed a site wide walk down and identified three additional scaffolds that exceeded the minimum clearance requirement. These scaffolds were subsequently removed. On February 18, 2014, the inspectors performed another plant walk down and identified an additional scaffold in contact with the 121 control room chilled water system. The inspectors communicated this additional observation to the licensee. The licensee initiated CAP 1419465 and performed an additional walk down of all erected scaffolds which identified no concerns. The inspectors performed a third walk down and concurred with the licensees results.
While reviewing this issue further, the inspectors interviewed maintenance, operations and engineering staff. Through the interview process, the inspectors determined that several plant staff lacked a thorough understanding of the D80 procedure. The inspectors were concerned that some maintenance and operations staff had the mindset that engineering had justified and authorized scaffold builds erected within 2 inches of plant equipment and that it was acceptable to exceed the 1 inch minimum requirement if necessary.
Analysis:
The inspectors determined that the failure to erect scaffolds in accordance with the requirements provided in Procedure D80 was a performance deficiency that was required to be evaluated using the Significance Determination Process. The inspectors determined that this issue was more than minor because it adversely impacted the protection against external factors attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, multiple scaffolds were erected in contact with safety-related equipment or within the minimum clearance proximity without adequate engineering justification. These configurations could have challenged the availability, reliability or capability of safety-related systems during a seismic event.
The inspectors utilized IMC 0609, Significance Determination Process, 0609.04, Initial Characterization of Findings, and determined that this issue was of very low safety significance (Green) because each question provided in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, was answered No. The inspectors concluded that this finding was associated with a conservative bias cross-cutting aspect in the human performance cross-cutting area.
Specifically, workers did not utilize prudent decision making practices while erecting scaffolding near safety-related equipment to ensure the clearance requirements were satisfied in accordance with Procedure D80 (H.14).
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The licensee established Procedure D80, Scaffolding, Ladders and Cable Trays Platforms, Revision 27, as the implementing procedure for erecting scaffolds, an activity affecting quality.
Procedure D80, Step 3.1.3 stated, The minimum clearance requirement for scaffold to operating equipment is 2 inches including range of operation of equipment. The minimum clearance can be reduced to 1 inch if approval is obtained from Engineering.
Contrary to the above, prior to February 13, 2014, the licensee failed to accomplish scaffold erection in accordance with Procedure D80. Specifically, licensee personnel failed to ensure scaffolding erected adjacent to safety-related equipment met the clearance requirements. In addition, scaffolds erected within one inch of safety-related equipment did not have an adequate engineering justification to verify the configuration would be acceptable during a seismic event. Because this violation was of very low safety significance and was entered into the licensees CAP as CAPs 1418846 and 1419465, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000282/2014002-01, Failure to Implement the Scaffolding, Ladders and Cable Trays Platforms Procedure). Corrective actions for this issue included walking down all scaffolds erected onsite and removing those that failed to comply with procedural requirements, briefing maintenance, operations and engineering staff on scaffolding clearance requirements, and a future revision to Procedure D80 to better clarify the minimum clearance requirements.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- 12 EHC pump testing following planned maintenance;
- 12 EHC unloader valve testing following planned maintenance;
- 21 SBSVS testing following differential pressure switch replacement;
- 4KV safeguards breaker maintenance and relay trip testing on breaker CT11-6;
- D1 EDG testing following preventative maintenance and starting air relief valve replacement; and
- Train A RHR system testing following preventative maintenance.
These activities were selected based upon the SSCs ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R20 Outage Activities
.1 Refueling Outage Activities
a. Inspection Scope
Refueling Outage 2R28 began on September 20, 2013. The inspectors observed multiple outage activities which were documented in NRC Inspection Reports 05000282/2013004; 05000306/2013004 and 05000282/2013005; 05000306/2013005.
During this inspection period, the inspectors continued to review the licensees controls over the 2R28 activities listed below:
- monitoring of decay heat removal processes, systems, and components;
- licensee fatigue management, as required by 10 CFR 26, Subpart I;
- startup and ascension to full power operation; and
- licensee identification and resolution of problems related to RFO activities.
Documents reviewed are listed in the Attachment to this report.
When combined with the inspection activities completed previously, this inspection constituted one RFO sample as defined in IP 71111.20-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- SP 1101 - 22 Motor-Driven Auxiliary Feedwater Pump Quarterly Flow and Valve Test (routine);
- SP 2032B - Unit 2 Train B Safeguards Logic Testing Train (routine);
- SP 2035B - Unit 2 Train B Reactor Protection Logic Test at Power (routine); and
- SP 2093 - Unit 2 D5 Emergency Diesel Generator Slow Speed Monthly Test (routine).
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted five routine surveillance testing samples and one inservice testing sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on March 25, 2014, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.
This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.
b. Findings
No findings were identified.
.2 Training Observation
a. Inspection Scope
The inspector observed a simulator training evolution for licensed operators on January 25, 2014, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.
This inspection of the licensees training evolution with emergency preparedness drill aspects constituted one sample as defined in IP 71114.06-06.
b. Findings
No findings were identified.
RADIATION SAFETY
2RS2 Occupational As-Low-As-Reasonably-Achievable Planning and Controls
This inspection constituted a partial sample as defined in IP 71124.02-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors reviewed the plants 3-year rolling average (TYRA) collective exposure.
The inspectors reviewed the site-specific trends in collective exposures and source term measurements.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures as-low-as-reasonably-achievable (ALARA), which included a review of processes used to estimate and track exposures from specific work activities.
b. Findings
No findings were identified.
.2 Verification of Dose Estimates and Exposure Tracking Systems (02.03)
a. Inspection Scope
The inspectors evaluated whether the licensee established measures to track, trend, and, if necessary, to reduce occupational doses for ongoing work activities. The inspectors assessed whether trigger points or criteria were established to prompt additional reviews and/or additional ALARA planning and controls.
The inspectors evaluated the licensees method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered. The inspectors assessed whether adjustments to exposure estimates (intended dose) were based on sound radiation protection and ALARA principles, or if they were just adjusted to account for failures to control the work. The inspectors evaluated whether the frequency of these adjustments called into question the adequacy of the original ALARA planning process.
b. Findings
No findings were identified.
.3 Problem Identification and Resolution (02.06)
a. Inspection Scope
The inspectors evaluated whether problems associated with ALARA planning and controls are being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the CAP.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation
This inspection constituted a partial sample as defined in IP 71124.05-05.
.1 Inspection Planning and Identification of Instrumentation (02.01)
a. Inspection Scope
The inspectors reviewed the USAR to identify radiation instruments associated with monitoring area radiological conditions including airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspectors reviewed the instrumentation and the associated TS requirements for post-accident monitoring instrumentation including instruments used for remote emergency assessment.
The inspectors reviewed a listing of in-service survey instrumentation including air samplers and small article monitors, along with instruments used to detect and analyze workers external contamination. Additionally, the inspectors reviewed personnel contamination monitors and portal monitors, including whole-body counters (WBCs), to detect workers internal contamination. The inspectors reviewed this list to assess whether an adequate number and type of instruments were available to support operations.
The inspectors reviewed licensee and third-party evaluation reports of the Radiation Monitoring Program since the last inspection. These reports were reviewed for insights into the licensees program and to aid in selecting areas for review (smart sampling).
The inspectors reviewed procedures that govern instrument source checks and calibrations, focusing on instruments used for monitoring transient high radiological conditions, including instruments used for underwater surveys. The inspectors reviewed the calibration and source check procedures for adequacy and as an aid to smart sampling.
The inspectors reviewed the area radiation monitor alarm set-point values and set-point bases as provided in the TSs and the USAR.
The inspectors reviewed effluent monitor alarm set-point bases and the calculational methods provided in the Offsite Dose Calculation Manual (ODCM).
b. Findings
No findings were identified.
.2 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down effluent radiation monitoring systems, including at least one liquid and one airborne system. Focus was placed on flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors of the selected systems. The inspectors assessed whether the effluent/process monitor configurations aligned with ODCM descriptions and observed monitors for degradation and out-of-service tags.
The inspectors selected portable survey instruments that were in use or available for issuance and assessed calibration and source check stickers for currency as well as instrument material condition and operability.
The inspectors observed licensee staff performance as the staff demonstrated source checks for various types of portable survey instruments. The inspectors assessed whether high-range instruments were source checked on all appropriate scales.
The inspectors walked down area radiation monitors and continuous air monitors to determine whether they were appropriately positioned relative to the radiation sources or areas they were intended to monitor. Selectively, the inspectors compared monitor response (via local or remote control room indications) with actual area conditions for consistency.
The inspectors selected personnel contamination monitors, portal monitors, and small article monitors and evaluated whether the periodic source checks were performed in accordance with the manufacturers recommendations and licensee procedures.
b. Findings
No findings were identified.
.3 Laboratory Instrumentation (02.04)
a. Inspection Scope
The inspectors assessed laboratory analytical instruments used for radiological analyses to determine whether daily performance checks and calibration data indicated that the frequency of the calibrations was adequate and there were no indications of degraded instrument performance.
The inspectors assessed whether appropriate corrective actions were implemented in response to indications of degraded instrument performance.
b. Findings
No findings were identified.
.4 Whole Body Counter (02.05)
a. Inspection Scope
The inspectors reviewed the methods and sources used to perform WBC functional checks before daily use of the instrument and assessed whether check sources were appropriate and aligned with the plants isotopic mix.
The inspectors reviewed WBC calibration records since the last inspection and evaluated whether calibration sources were representative of the plant source term and that appropriate calibration phantoms were used. The inspectors looked for anomalous results or other indications of instrument performance problems.
b. Findings
No findings were identified.
.5 Post-Accident Monitoring Instrumentation (02.06)
a. Inspection Scope
The inspectors selected containment high-range monitors and reviewed the calibration documentation since the last inspection and assessed whether an electronic calibration was completed for all range decades above 10 rem/hour and whether at least one decade at or below 10 rem/hour was calibrated using an appropriate radiation source.
The calibration acceptance criteria were found to be reasonable, accounting for the large measuring range and the intended purpose of the instruments.
The inspectors selected effluent/process monitors that were relied on by the licensee in its emergency operating procedures as a basis for triggering emergency action levels and subsequent emergency classifications, or to make protective action recommendations during an accident. The inspectors evaluated the calibration and availability of these instruments. In addition the inspectors reviewed the licensees capability to collect high-range, post-accident iodine effluent samples.
As available, the inspectors observed electronic and radiation calibration of these instruments to assess conformity with the licensees calibration and test protocols.
b. Findings
No findings were identified.
.6 Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors (02.07)
a. Inspection Scope
For each type of these instruments used on site, the inspectors assessed whether the alarm set-point values were reasonable under the circumstances to ensure that licensed material is not released from the site. The inspectors reviewed the calibration documentation for each instrument selected and discussed the calibration methods with the licensee to determine consistency with the manufacturers recommendations.
b. Findings
No findings were identified.
.7 Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air
Samplers/Continuous Air Monitors (02.08)
a. Inspection Scope
The inspectors reviewed calibration documentation for at least one of each type of instrument. For portable survey instruments and area radiation monitors, the inspectors reviewed detector measurement geometry and calibration methods and had the licensee demonstrate use of its instrument calibrator as applicable. The inspectors conducted comparison of instrument readings versus an NRC survey instrument if problems were suspected.
As available, the inspectors selected portable survey instruments that did not meet acceptance criteria during calibration or source checks to assess whether the licensee had taken appropriate corrective action for instruments found significantly out of calibration (e.g., greater than 50 percent). The inspectors evaluated whether the licensee evaluated the possible consequences of instrument use since the last successful calibration or source check.
b. Findings
No findings were identified.
.8 Instrument Calibrator
a. Inspection Scope
As applicable, the inspectors reviewed the current output values for the licensees portable survey and area radiation monitor instrument calibrator unit(s). The inspectors assessed whether the licensee periodically measures calibrator output over the range of the instruments used through measurements by ion chamber/electrometer.
The inspectors assessed whether the measuring devices had been calibrated by a facility using National Institute of Standards and Technology traceable sources and whether corrective factors for these measuring devices were properly applied by the licensee in its output verification.
b. Findings
No findings were identified.
.9 Calibration and Check Sources (02.09)
a. Inspection Scope
The inspectors reviewed the licensees 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, source term to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.
b. Findings
No findings were identified.
.10 Problem Identification and Resolution (02.10)
a. Inspection Scope
The inspectors evaluated whether problems associated with radiation monitoring instrumentation were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring instrumentation.
b. Findings
No findings were identified.
2RS8 Occupational Dose Assessment
This inspection constituted one radioactive solid waste processing and radioactive material handling, storage, and transportation sample as defined in IP 71124.08-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the solid radioactive waste system description in the USAR, the Process Control Program (PCP), and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.
The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensees performance and inform the smart sampling inspection planning.
b. Findings
No findings were identified.
.2 Radioactive Material Storage (02.02)
a. Inspection Scope
The inspectors selected areas where containers of radioactive waste were stored and evaluated whether the containers were labeled in accordance with 10 CFR 20.1904, Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to Labeling Requirements, as appropriate.
The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20, Standards for Protection against Radiation. For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, Security of Stored Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.
The inspectors evaluated whether the licensee established a process for monitoring the impact of long term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.
The inspectors selected containers of stored radioactive material and assessed for signs of swelling, leakage and deformation.
b. Findings
No findings were identified.
.3 Radioactive Waste System Walkdown (02.03)
a. Inspection Scope
The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in the USAR, ODCM, and PCP.
The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment which is not in service or abandoned in place, would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure.
The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, Changes, Tests, and Experiments.
The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes from what is described in the USAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate and to assess the impact on radiation doses to members of the public.
The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, Waste Classification.
For those systems that provide tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing.
The inspectors assessed whether the licensees PCP correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid).
b. Findings
No findings were identified.
.4 Waste Characterization and Classification (02.04)
a. Inspection Scope
The inspectors selected the following radioactive waste streams for review:
- Bead Resin;
- Dry Active Waste;
- High Level Filters;
- Low Level Filters; and
- Steam Generator Blow Down Resin.
For the waste streams listed above, the inspectors assessed whether the licensees radiochemical sample analysis results (i.e., 10 CFR Part 61" analysis) were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated whether the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analysis for the selected radioactive waste streams.
The inspectors evaluated whether changes to plant operational parameters were taken into account to:
- (1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and
- (2) assure that waste shipments continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above.
The inspectors evaluated whether the licensee established and maintained an adequate Quality Assurance Program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste Characteristics.
b. Findings
No findings were identified.
.5 Shipment Preparation (02.05)
a. Inspection Scope
The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for cask loading and closure procedures were consistent with the vendors current approved procedures.
The inspectors observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation and receipt activities. The inspectors assessed whether the shippers were knowledgeable of the shipping regulations and whether shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to:
- As appropriate, the licensees response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, dated August 10, 1979;
- Title 49 CFR Part 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirement, and Security Plans, Subpart H, Training.
b. Findings
No findings were identified.
.6 Shipping Records (02.06)
a. Inspection Scope
The inspectors evaluated whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number for the following radioactive shipments:
- Shipping Record 13-047; Radioactive Waste Shipment Old Steam Generators Upper Section;
- Shipping Record 13-048; Radioactive Waste Shipment Old Steam Generators Upper Section;
- Shipping Record 13-052; Radioactive Waste Shipment Old Steam Generators Lower Section; and
- Shipping Record 13-053; Radioactive Waste Shipment Old Steam Generators Lower Section.
Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation.
b. Findings
No findings were identified.
.7 Identification and Resolution of Problems (02.07)
a. Inspection Scope
The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensees CAP. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation.
The inspectors reviewed results of selected audits performed since the last inspection of this program and evaluated the adequacy of the licensees corrective actions for issues identified during those audits.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours performance indicator (PI) for Units 1 and 2 for the period from the first quarter of 2013 through the fourth quarter of 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CAPs, event reports and NRC Integrated Inspection Reports for the period of the first quarter through the fourth quarter of 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two unplanned scrams per 7000 critical hours samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Unplanned Scrams with Complications
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams with Complications performance indicator Units 1 and 2 for the period from the first quarter of 2013 through the fourth quarter of 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CAPs, event reports and NRC Integrated Inspection Reports for the period of the first quarter through the fourth quarter of 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two unplanned scrams with complications samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Unplanned Transients per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours performance indicator Units 1 and 2 for the period from the first quarter of 2013 through the fourth quarter of 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CAPs, maintenance rule records, event reports and NRC Integrated Inspection Reports for the period of first quarter of 2013 through the fourth quarter of 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees corrective action database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two unplanned transients per 7000 critical hours samples as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; 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 that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
.3 Selected Issue Follow-Up Inspection: Review of Corrective Actions Taken in Response
to CAP 1403558, Main Steam Piping Re-analysis Inappropriately Conservative
a. Inspection Scope
During a review of items entered in the licensees CAP, the inspectors discovered a corrective action document regarding a re-analysis of the Unit 2 main steam lines for torsional acceleration. The inspectors were initially concerned that information in the CAP failed to address whether torsional acceleration issues existed on the Unit 1 main steam lines. The inspectors reviewed the Unit 1 main steam piping analysis to determine whether torsional accelerations were considered in the analysis of record.
The inspectors determined that the Unit 1 main steam line analysis of record was acceptable because it demonstrated compliance with the current licensing basis requirements.
This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.
b. Findings
No findings were identified.
.4 Selected Issue Follow-up Inspection: Use of Designated Operator to Eliminate Need to
Accrue System Unavailability During Surveillance Testing
a. Inspection Scope
Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guidelines, provides NRC licensees with guidelines that must be met as part of the PI reporting process. Appendix F of NEI 99-02 allowed licensees to exclude system unavailability hours accrued during surveillance testing from their PI reports if a designated operator could take action to restore the system during an emergency.
However, NEI 99-02 stated that the designated operator must be stationed locally for the sole purpose of performing the restoration actions, the actions must be proceduralized, and the actions needed to consist of only one action or a few simple actions.
While observing cooling water pump surveillance testing in 2012, the inspectors identified that the licensee was not properly adhering to industry guidelines regarding the use of designated operators. Specifically, the inspectors observed the designated operator performing other activities during the testing rather than being dedicated to performance of the system restoration actions. As a result, the inspectors questioned the accuracy of the licensees cooling water system PIs. The inspectors reviewed the licensees PI bases document and system unavailability data for each of the safety-related systems monitored by the NRCs PI program. The inspectors identified similar concerns with the auxiliary feedwater and RHR systems. The licensee reviewed the inspectors concerns and provided updated PI data to the NRC. While the failure to report accurate PI data to the NRC was a violation of 10 CFR 50.9, this violation was considered minor as none of the PIs changed color.
During the first quarter of 2014, the inspectors observed surveillance testing on multiple systems to ensure that the licensee was complying with the guidance provided in NEI 99-02 regarding the use of designated operators. The inspectors also reviewed a sampling of PI system unavailability information to assess whether the licensee was properly reporting this data to the NRC.
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Institute of Nuclear Power Operations (INPO) Plant Assessment Report Review
a. Inspection Scope
The inspectors reviewed the final report for the INPO plant assessment conducted in August 2013. The inspectors reviewed the report to ensure that issues identified were consistent with the NRC perspectives of licensee performance and to verify if any significant safety issues were identified that required further NRC follow-up.
b. Findings
No findings were identified.
.2 Summary of Revised Cross-Cutting Aspects for 3rd and 4th Quarter 2013 Inspection
Findings The table below provides a cross-reference from the third and fourth quarter 2013 findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.
Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect 05000282/2013004-01; H.3(a) H.5 05000306/2013004-01 05000282/2013004-02; H.3(a) H.5 05000306/2013004-02 05000282/2013004-03; H.1(b) H.14 05000306/2013004-03 05000282/2013004-04 H.4(c) H.2 05000252/2013405; H.4(c) H.2 05000306/2013405 05000306/2013005-01 H.1(b) H.14 05000282/2013005-02; H.2(c) H.7 05000306/2013005-02 05000282/2013005-03 P.1(c) P.2
4OA6 Management Meetings
.1 Exit Meeting Summary
On April 3, 2014, the inspectors presented the inspection results to Mr. Kevin Davison, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The inspection results for the areas of occupational ALARA planning and controls; radiation monitoring instrumentation; and radioactive solid waste processing and radioactive material handling, storage, and transportation with Mr. Kevin Davison, Site Vice President, on February 14, 2014.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- K. Davison, Site Vice President
- S. Sharp, Director - Site Operations
- J. Hallenbeck, Site Engineering Director
- T. Allen, Assistant Plant Manager
- J. Anderson, Regulatory Affairs Manager
- J. Boesch, Maintenance Manager
- T. Borgen, Training Manager
- B. Boyer, Radiation Protection Manager
- H. Butterworth, Nuclear Oversight Manager
- F. Calia, Business Support Manager
- J. Corwin, Security Manager
- K. DeFusco, Emergency Preparedness Manager
- D. Gauger, Chemistry/Environmental Manager
- G. Johnson, Senior Manager Site Engineering
- S. Lappegaard, Production Planning Manager
- B. Meek, Safety and Human Performance Manager
- J. Ruttar, Operations Manager
Nuclear Regulatory Commission
- K. Riemer, Chief, Reactor Projects Branch 2
- S. Wall, Project Manager, Office of Nuclear Reactor Regulation
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000282/2014002-01 NCV Failure to Implement the Scaffolding, Ladders and Cable Trays Platforms Procedure (1R15)
Closed
- 05000282/2014002-01 NCV Failure to Implement the Scaffolding, Ladders and Cable Trays Platforms Procedure (1R15)
Discussed
None