IR 05000321/2006004

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IR 05000321-06-004, 05000366-06-004, and 072000036-06-002, on 07/01/2006 - 09/30/2006, for Edwin I. Hatch, Units 1 and 2, Identification and Resolution of Problems
ML063030307
Person / Time
Site: Hatch, 07200036  Southern Nuclear icon.png
Issue date: 10/03/2006
From: Scott Shaeffer
NRC/RGN-II/DRP/RPB2
To: Stinson L
Southern Nuclear Operating Co
References
FOIA/PA-2010-0209 IR-06-004
Download: ML063030307 (31)
v • d • e


Text

ber 30, 2006

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2006004, 05000366/2006004, AND 072000036/2006002

Dear Mr. Stinson:

On September 30, 2006, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection results, which were discussed on October 13, 2006, with Mr. Dennis Madison 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.

This report documents one NRC-identified finding which was assessed using traditional enforcement as a Severity Level lV violation. However, because of the low severity level and because it has been entered into your corrective action program, the NRC is treating this violation as a non-cited violation (NCV) in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest this NCV, you should provide a written response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC, 20555-0001; and the NRC Senior Resident Inspector at the Hatch Nuclear Plant.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-321, 50-366, and 72-36 License Nos. DPR-57 and NPF-5

Enclosure:

Inspection Report 05000321/2006004, 05000366/2006004, and 072000036/2006002 w/Attachment: Supplemental Information

__

OFFICE RII/DRP RII/DRP RII/DRP RII/DRP RII/DRS RII/DRS RII/DRS RII/DRS SIGNATURE CWR /RA/ via email via email via email via email via email via email NAME C. Rapp S. Shaeffer D. Simpkins J. Hickey W. Loo N. Griffis J. Díaz R. Carrion DATE 10/23/2006 10/23/2006 10/20/2006 10/20/2006 10/20/2006 10/30/2006 10/23/2006 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO

REGION II==

Docket Nos.: 50-321, 50-366, 72-36 License Nos.: DPR-57 and NPF-5 Report Nos.: 05000321/2006004, 05000366/2006004, and 072000036/2006002 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, Georgia 31515 Dates: July 1 - September 30, 2006 Inspectors: D. Simpkins, Senior Resident Inspector J. Hickey, Resident Inspector W. Loo, Senior Health Physicist (Sections 2OS3 and 4OA5)

N. Griffis, Health Physicist (Section 2PS1)

J. Díaz Vélez, Health Physicist (Sections 2PS3 and 4OA1)

R. Carrion, Project Engineer (Sections 2OS1 and 4OA1)

Approved by: Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000321/2006-004, 05000366/2006-004, 07200036/2006-002; 07/01/2006-09/30/2006;

Edwin I. Hatch Nuclear Plant, Units 1 and 2, Identification and Resolution of Problems The report covered a three-month period of inspection by resident inspectors, health physicists, and a project engineer. One Severity Level (SL) IV non-cited violation (NCV) was identified.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using 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-Revealing Findings

Cornerstone: Mitigating Systems

  • SL IV. An NRC-identified non-cited violation of 10 CFR 50.73 (a)(2)(i)(B) was identified for failure to report past conditions prohibited by plant Technical Specifications (TS). The inspectors determined that, during the most recent operating cycle for both Units 1 and 2, several main steam safety/relief valves exceeded the TS lift setting tolerance. These represented reportable events.

This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact the NRCs ability to perform its regulatory function. This finding was determined to be a Severity Level IV violation based on Supplement I of the NRC Enforcement Policy. (Section 4OA2)

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at or near 100% Rated Thermal Power (RTP). On July 30, power was reduced to 40% RTP when a relay failure caused a runback of the 1A Recirculation Pump. The unit was returned to 100% RTP on August 2. On August 10, a problem with the 1B Reactor Feed Pump speed control resulted in a load reduction to 80% RTP. The unit was returned to 100% RTP on August 13 and remained at 100% RTP through the end of the reporting period.

Unit 2 began the inspection period at or near 100% RTP. On September 25, a load reduction to 80% RTP was performed to repair an oil leak on the 2B Reactor Feed Pump. Unit 2 was returned to 100% RTP on September 26 and remained at 100% RTP through the end of the reporting period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather

a. Inspection Scope

Imminent Adverse Weather. The inspectors reviewed licensee actions in response to anticipated high winds resulting from Tropical Storm Ernesto. The inspectors reviewed licensee procedure 34AB-Y22-002-0, Naturally Occurring Phenomena, and walked down external plant areas to ensure debris and loose materials were controlled to limit missile hazards especially near switchyards and safety-related equipment.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdowns. The inspectors performed partial walkdowns of the following four systems when the opposite trains were removed from service. The inspectors checked system valve, electrical breaker, and operating switch positions to evaluate the operability of the opposite trains or components by comparing the position listed in the system operating procedure to the actual position. Documents reviewed are listed in the

.

  • B and C trains of the Main Control Room Air Conditioning (MCRAC) during maintenance on the A train MCRAC.
  • A and C MCRAC system during maintenance on the B MCRAC
  • Unit 1 Vital AC system during maintenance on portions of the system

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

Fire Area Tours. The inspectors toured the following 12 risk significant plant areas to assess the material condition of the fire protection and detection equipment, verify fire protection equipment was not obstructed, and that transient combustibles were properly controlled. The inspectors reviewed the Fire Hazards Analysis drawings H-11846 and H-11847 to verify that the necessary fire fighting equipment, such as fire extinguishers, hose stations, ladders, and communications equipment, were in place. Documents reviewed are listed in the Attachment.

  • Unit 1 Standby Gas and HVAC 164' elevation
  • Unit 1 Reactor Building working floor and Air Supply Room 203
  • Refueling Floor
  • Unit 2 High Pressure Core Injection Room
  • Unit 2 CRD area 130'
  • Unit 2 Reactor Building working floor 158' elevation
  • Unit 2 Recirculation pump Motor Generator Set rooms 158' elevation
  • Unit 2 Chiller Room 164' elevation

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

Resident Quarterly Observation. The inspectors observed the performance of licensee simulator scenario LR-SE-00020-18 which included a trip of the 2A reactor feed pump turbine, control rod insertion to comply with the requirements of the power to flow map, main turbine trip, RPS auto scram failure, loss of normal feed capability, loss of torus water level and emergency depressurization. The inspectors reviewed licensee procedures 10AC-MGR-019-0S, Procedure Use and Adherence, and DI-OPS-59-0896N, Operations Management Expectations, to verify formality of communication, procedure usage, alarm response, control board manipulations, group dynamics, and supervisory oversight. The inspectors attended the post-exercise critique of operator performance to assess if the licensee identified performance issues were comparable to those identified by the inspectors. In addition, the inspectors reviewed the critique results from previous training sessions to assess performance improvement.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the following two maintenance activities associated with structures, systems, and components (SSCs) to assess the licensees implementation of the Maintenance Rule (10 CFR 50.65) with respect to the characterization of failures and the appropriateness of the associated (a)(1) or (a)(2) classification. The inspectors reviewed operator logs, associated Condition Reports (CR), Maintenance Work Orders (MWO) and the licensees procedures for implementing the Maintenance Rule. The review was to determine if equipment failures were being identified, properly assessed, and corrective actions established to return the equipment to a satisfactory condition.

Documents reviewed are listed in the Attachment.

  • B MCRAC Ventilation System Outage
  • 1A RHR Pump High Vibrations

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the following seven Plan of the Day (POD) documents listed below to verify that risk assessments were performed prior to components being removed from service. The inspectors reviewed the risk assessment and risk management controls implemented for these activities to verify they were completed in accordance with licensee procedure 90AC-OAM-002-0, Scheduling Maintenance, and 10 CFR 50.65 (a)(4). For emergent work, the inspectors assessed if any increase in risk was promptly assessed and that appropriate risk management actions were implemented.

  • POD for Week of 7/8-14
  • POD for Week of 7/29-8/4
  • POD for Week of 8/5-11
  • POD for Week of 8/12-18
  • POD for Week of 8/26-9/1
  • POD for Week of 9/2-8
  • POD for Week of 9/16-22

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following six operability evaluations and compared the evaluations to the system requirements identified in the Technical Specifications and the Final Safety Analysis Report (FSAR) to ensure operability was adequately assessed and the system or component remained available to perform its intended function. Also, the inspectors assessed the adequacy of compensatory measures implemented as a result of the condition. Documents reviewed are listed in the Attachment.

  • 1F 4160 Bus undervoltage time delay relay as found value greater than allowed by TS
  • Abnormal Vibrations on the 1A and 1C RHR Pumps

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the following seven post maintenance tests, the inspectors reviewed the test scope to verify the test demonstrated the work performed was completed correctly and the affected equipment was functional and operable in accordance with TS requirements.

The inspectors reviewed equipment status and alignment to verify the system or component was available to perform the required safety function. Documents reviewed are listed in the Attachment.

  • Unit 1 RCIC 1E51K52 relay replacement
  • Unit 2 RCIC room cooler control valve 2P41F040A inspection
  • Unit 2 RHR Pump 2A cooler control valve 2P41F037A inspection
  • Unit 2 RHR Pump 2C cooler control valve 2P41F037C actuator rebuild
  • 1A EDG fuel oil pump running indication resistor replacement
  • Removal of TMM 1-06-020, Temporary bracing on the 1A RHR Pump

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed licensee surveillance test procedures and either witnessed the test or reviewed test records for the following six surveillances to determine if the scope of the test adequately demonstrated the affected equipment was operable. The inspectors reviewed these activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance. The inspectors reviewed licensee procedure AG-MGR-21-0386N, Evolution and Pre-and Post-Job Brief Guidance, and attended selected briefings to determine if procedure requirements were met. Documents reviewed are listed in the

.

Surveillance Tests

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following two temporary modifications (TMM) and assessed the evaluation using criteria defined in licensee procedure 40AC-ENG-018-0S, Temporary Modification Control. In addition, the 10 CFR 50.59 evaluation was assessed using the design basis information provided in the FSAR to verify the modification did not affect the safety functions of this system. The inspectors also verified the modification was installed in accordance with the TMM requirements.

  • TMM 1-06-019, Tritium Collection System
  • TMM 1-06-020, Temporary Bracing on the 1A RHR Pump

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the following emergency plan off-hours drill. The inspectors observed licensee activities in the simulator, Technical Support Center and Operations Support Center to verify implementation of licensee procedure 10AC-MGR-006-0, Hatch Emergency Plan. The inspectors reviewed the classification of the simulated events and the development of protective action recommendations to verify these activities were conducted in accordance with licensee procedure 73EP-EIP-001-0, Emergency Classification and Initial Actions. The inspectors also reviewed licensee procedure 73EP-EIP-073-0, Onsite Emergency Notification, to verify the proper offsite notifications were made. The inspectors discussed the post-exercise critique with plant staff to assess the licensees effectiveness in identifying areas of improvement. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety 2OS1 Access Control To Radiologically Significant Areas

a. Inspection Scope

The inspectors reviewed and evaluated licensee guidance and its implementation for controlling and monitoring worker access to radiologically significant areas and tasks associated with Unit 1 and Unit 2 operations. The inspectors evaluated changes to and adequacy of procedural guidance; directly observed implementation of established administrative and physical radiation controls; appraised occupational worker and health physics technician (HPT) knowledge of and proficiency in implementing radiation protection (RP) activities; and assessed occupational worker exposures to radiation and radioactive material.

The inspectors directly observed controls established for workers and HPT staff involved in work/tasks associated with actual/potential airborne radioactivity area, radiation area, high radiation area (HRA), locked high radiation area (LHRA), and very high radiation area (VHRA) conditions. Controls and their implementation for LHRA keys and for storage of irradiated material within the Unit 1 spent fuel pool were reviewed and discussed in detail. Established radiological controls were evaluated for selected tasks including work conducted on the refueling floor and radiography for the Unit 1 and Unit 2 plant service water systems. In addition, licensee controls for areas where dose rates could change significantly as a result of plant operations were reviewed and discussed.

For selected tasks, the inspectors attended pre-job briefings and reviewed radiation work permit (RWP) details to assess communication of radiological control requirements to workers. Occupational workers adherence to selected RWPs and HPT proficiency in providing job coverage were evaluated through direct observations and interviews with licensee staff. Worker exposure as measured by electronic dosimeter was reviewed and assessed independently.

During facility tours within the radiologically controlled areas (RCA), the inspectors observed and evaluated postings and physical controls established for access to the Unit 1 and 2 reactor buildings; selected control building locations/equipment; and selected turbine building locations/equipment. The inspectors independently measured radiation dose rates and contamination levels associated with selected Unit 2 reactor building and radioactive waste processing areas/equipment. Results were compared to current licensee surveys and assessed against established postings and radiation controls.

The inspectors evaluated implementation and effectiveness of licensee controls for both airborne and external radiation exposure. Effectiveness of external radiation exposure controls was evaluated through review and discussions of individual worker dose as measured by electronic dosimeter for selected tasks.

RP activities were evaluated against the FSAR, TS, and 10CFR Parts 19 and 20 requirements. Specific assessment criteria included FSAR Section 12, Radiation Protection; 10 CFR 19.12; 10 CFR 20, Subparts B, C, F, G, H, and J; TS Sections 5.4, Procedures and 5.7, High Radiation Areas; and approved licensee procedures.

Licensee guidance documents, records, and data reviewed are listed in the Attachment.

The inspectors completed 21 of the required 21 samples.

Problem Identification and Resolution. Licensee corrective action program (CAP)documents and CRs associated with access control to radiologically significant areas were reviewed and assessed. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure NMP-GM-002-GL02, Corrective Action Program Details and Expectations Guideline, Version 4.0. In addition, the inspectors reviewed two self-assessments conducted since the last NRC inspection of these areas as well as Outage Information Reports for the last refueling outage of Unit 1 (in 2006) and Unit 2 (in 2005).

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment

a. Inspection Scope

Radiation Monitors. The operability, reliability, and maintenance of area radiation monitors (ARM) and continuous air monitors (CAM) were reviewed and evaluated.

During plant walkdowns, the inspectors examined the material condition and verified current calibration dates for selected fixed ARMs, portable ARMs, and CAMs. The inspectors also reviewed documentation of performance checks and calibrations for selected monitors. Licensee program activities in this area were reviewed against requirements specified in applicable procedures and in Chapters 7, 11, and 12 of the FSAR. Licensee procedures, records, data, and other documents reviewed are listed in the Attachment.

Portable and Personnel Survey Instrumentation. Current program guidance, including procedures for calibration and operation, and its implementation to maintain operability and accuracy of selected personnel survey instrumentation, were reviewed and evaluated. The inspectors reviewed current calibration data for selected portable survey instruments, and assessed operability of various survey instruments staged or in use by HP staff. Responsible staffs knowledge and proficiency regarding portable survey instrument calibration activities were evaluated through interviews, record reviews, and observations of plant activities. The accuracy and operability determinations for instrumentation used to perform surveys in HRAs, LHRAs, and VHRAs were assessed.

Operability and analysis capabilities of the licensees whole-body counter (WBC),personnel contamination monitor (PCM), and portal monitor (PM) equipment were reviewed and evaluated. For the WBC and selected PCMs and PMs, current calibration and recent operational/performance test surveillance data were evaluated. For selected PMs and PCMs located at the main RCA exit (C-52) and the Turbine Building RCA exits (T-16 and T-17), the inspectors directly observed equipment responses to mixed plant-specific radioactive sources positioned at various orientations and distances from the individual detectors to simulate potential worker contamination.

Licensee activities associated with personnel radiation monitoring instrumentation were reviewed against TS, 10 CFR 20.1501, and applicable licensee procedures listed in the

.

Respiratory Protection Equipment - Self-Contained Breathing Apparatus (SCBA). The licensees respiratory protection program guidance and its implementation for SCBA use were evaluated. The SCBA units staged for emergency use in the Control Room and other selected locations were inspected for material condition, air pressure, and number of units available. The inspectors reviewed and evaluated maintenance of SCBA equipment and certification records associated with supplied air quality. Proficiency and knowledge of staff responsible for maintaining SCBA equipment were evaluated through discussions, demonstrations of SCBA functional checks, and review of training records.

Select Control Room operations personnel were interviewed to determine their knowledge of available SCBA equipment locations, including corrective lens inserts if needed, and their training on replacement of air bottles during extended usage periods.

The inspectors assessed the licensees arrangements for transporting replacement air bottles from the onsite refill station (located in an outlying building within the Protected Area) to the Control Room and Operational Support Center. Licensee activities associated with maintenance and use of SCBA equipment were reviewed against 10 CFR Part 20.1703; Regulatory Guide (RG) 8.15, Acceptable Programs for Respiratory Protection, Revision 1, October 1999; American National Standards Institute (ANSI)-Z88.2-1992, American National Standard Practices for Respiratory Protection; and applicable procedures listed in the Attachment.

The inspectors completed 9 of the required 9 samples.

Problem Identification and Resolution. Issues identified through Health Physics departmental self-assessments and CAP documents associated with radiation monitoring instrumentation and SCBA were reviewed and discussed with cognizant licensee representatives. The inspectors assessed the licensees ability to identify, characterize, prioritize, and resolve selected issues in accordance with licensee procedure NMP-GM-002-GL02. Special assessments and CRs reviewed and evaluated in detail for this inspection area are listed in the Attachment.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

a. Inspection Scope

Effluent Monitoring and Radwaste Equipment. During inspector walkdowns, accessible sections of the Unit 1 and Unit 2 liquid and gaseous radioactive waste (radwaste) and effluent systems were assessed for material condition and conformance with the FSAR.

The inspection included the Waste Sample Tanks, Floor Drain Sample Tanks, Chemical Waste Sample Tanks, Liquid Radwaste Discharge Monitors (1/2D11-N007), Unit 1 Off-gas System Post-Treatment Monitor (1D11-K615A and B), Unit 1 Recombiner Building Vent Monitor (1D11-R763A and B), Reactor Building Vent Monitors (D11-K619A and B /

2D11-K636A and B), Main Stack Monitor (D11-K600A and B), and associated airborne effluent sample lines. The inspectors interviewed chemistry and engineering staff regarding radwaste effluent monitor operation and equipment configuration requirements for representative sampling. The inspectors observed collection of particulate, iodine, and tritium samples from the main stack release pathway, and assessed those activities for procedural adherence.

The inspectors reviewed performance records and calibration results for selected radiation monitors, flowmeters, and air filtration systems. For monitors 1D11-K615B, D11-K619A and B, 2D11-K636A and B, 1D11-R763A and B, D11-K600A and B, and 1/2D11-N007, the inspectors reviewed the most recent calibration records. The inspectors also reviewed the last two functional/flow checks for these effluent monitors.

The inspectors reviewed out-of-service monitors from January 2004 to July 2006, and verified that required compensatory sampling was performed. The most recent surveillances on the Off-Gas High-Efficiency Particulate Air Filter Systems were reviewed. Performance and operations of the systems were reviewed and discussed with cognizant licensee personnel.

Current licensee programs for monitoring, tracking, and documenting the results of both routine and abnormal liquid releases to onsite and offsite surface and ground water environs were reviewed and discussed in detail. Specifically, the inspectors reviewed and discussed the effect of routine effluent liquid releases made in accordance with Offsite Dose Calculation Manual (ODCM) requirements on surface water and ground water station sample tritium concentrations. Tritium concentration results for ground water monitoring wells associated with the Unit 1 Condensate Storage Tank were reviewed and discussed in detail. Reports associated with abnormal liquid releases and corrective actions initiated since Calendar Year (CY) 1978 were reviewed and discussed with responsible licensee representatives to evaluate the potential onsite/offsite environmental impact of significant leakage/spills from onsite systems, structures, and components. Also, the inspector verified that these areas had been properly documented in the licensees site decommissioning files in accordance with 10 CFR 50.75(g), if required. Current licensee capabilities and routine surveillances to minimize and rapidly identify abnormal leaks from liquid radioactive waste tanks, processing lines, and spent fuel pools were reviewed and discussed in detail.

Installed configuration, material condition, operability, and reliability of selected effluent sampling and monitoring equipment were reviewed against details documented in the following: 10 CFR Part 20; RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants; TS, Section 5.0; the ODCM, Rev. 17; and FSAR. Documents reviewed are listed in the Attachment.

Effluent Release Processing and Quality Control (QC) Activities. The inspectors directly observed the collection of liquid waste samples and discussed the procedures and processes followed by chemistry personnel for obtaining waste gas samples and liquid effluent samples from waste monitor tanks. In addition, the inspectors discussed the process for performing liquid and gaseous releases with chemistry personnel in the radwaste facility control room. Chemistry technician proficiency in processing and counting effluent samples was evaluated.

QC activities associated with gamma spectroscopy were discussed with count room technicians and Chemistry supervision. The inspectors reviewed daily QC charts from June 1 to July 20, 2006, for High Purity Germanium (HPGe) detectors No. 1, 2, and 3; and reviewed licensee procedural guidance for count room QC activities. The inspectors reviewed calibration records for HPGe detector No. 1 (select counting geometries). In addition, results of the radiochemistry cross-check program for 2nd quarter 2005 through 1st quarter 2006 were reviewed and discussed with cognizant licensee staff.

Selected portions of procedures for effluent sampling, processing, and release were evaluated for consistency with licensee actions. Two liquid and four gaseous release permits were reviewed against ODCM specifications for pre-release sampling and effluent monitor setpoints. The inspectors discussed performance of pre-release sampling and analysis, release permit generation, and radiation monitor setpoint adjustment with chemistry technicians and radwaste control room operators. The inspectors reviewed the 2004 and 2005 Annual Radiological Effluent Release Reports to evaluate reported doses to the public and ODCM changes. Public dose calculations were reviewed and discussed with cognizant licensee personnel.

Observed task evolutions, count room activities, and offsite dose results were evaluated against details and guidance documented in the following: 10 CFR Part 20 and Appendix I to 10 CFR Part 50; ODCM; RG 1.21; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I; RG 1.33, Quality Assurance Program Requirements; and TS Section 5.0. Documents reviewed are listed the in Attachment.

The inspectors completed 10 of the required 10 samples.

Problem Identification and Resolution. Multiple CRs and a Self Assessment associated with effluent release activities were reviewed. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve selected issues in accordance with NMP-GM-002-GL02. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program

a. Inspection Scope

REMP Implementation. The licensees Annual Radiological Environmental Operating Reports for CY 2004 and CY 2005 were reviewed and discussed with cognizant licensee representatives. The inspectors discussed and evaluated the reported data for trends in radionuclide concentrations, anomalous/missing data, and land-use census information.

QC activities and data for selected sample types listed in the reports were reviewed and evaluated including inter-laboratory comparison results, analytical assumptions used in gross beta analyses, and calculations for air particulate gross beta lower limit of detection determinations. In addition, the inspectors reviewed the 1st quarter 2006 semiannual sample pump air flow calibration data.

Equipment operational status and staff proficiency in implementing REMP activities were assessed through review of records, observations of equipment material condition and operating characteristics, and through assessment of selected sample collection activities. Collection of weekly air particulate filters/charcoal cartridges and air flow rate determinations were observed at sampling locations 103, 107, 112, 116, 304, and 309.

The placement and material condition of surface water samplers at sample locations 170 and 172 were observed. A collection of milk samples at sampling location 304 was also observed and discussed with collection personnel. During observations of sample collection, the inspectors evaluated the proficiency of staff collecting the samples, and assessed the adequacy and implementation of selected collection techniques. The placement and material condition of thermoluminescent dosimetry (TLD) equipment were assessed at sample locations 064, 103, 107, 112, 304, and 309. Using Global Positioning System equipment, the inspectors independently assessed selected TLD and air sampling locations and compared the current location data to ODCM-specified locations. REMP guidance, implementation, and results were reviewed against the licensees ODCM and applicable procedures listed in the Attachment.

Meteorological Monitoring Program. Licensee program activities to assure accuracy and availability of meteorological monitoring data were evaluated through review of calibration and surveillance data and direct observation of equipment and readout data at the primary tower, backup tower, and control room. Equipment performance, reliability, and conduct of routine surveillances were discussed with technicians responsible for tower equipment maintenance and inspections. Meteorological availability data was reviewed and discussed with licensee representatives.

Meteorological data reviewed included data for CY 2004, CY 2005, and Year-To-Date March 2006. The inspectors also verified consistency between meteorological tower local readouts and control room data.

Meteorological instrument operation, calibration, and maintenance were reviewed against details listed in the FSAR, Chapter 2; NRC Safety Guide 23, Onsite Meteorological Programs-1972; ANSI -3.11-2000, Determining Meteorological Information; RG 1.21; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment, December 1977; and applicable licensee procedures. Documents reviewed are listed in the Attachment.

Unrestricted Release of Materials from the RCA. Radiation protection program activities associated with the unconditional release of potentially contaminated materials from RCA egress points were evaluated. Operability and analysis capabilities of the licensees Small Article Monitor (SAM) instruments were reviewed and evaluated. In addition, responsible staffs knowledge and proficiency regarding SAM instrument calibration activities were evaluated through interviews, record reviews, and direct observations of plant activities. For selected SAM instruments, current calibration and recent operational/performance test surveillance data were observed and evaluated.

For selected SAM instruments located at the main RCA exit (C-52) and the Turbine Building RCA exits (T-16 and T-17), the inspectors directly observed equipment responses to mixed plant-specific radioactive sources positioned at various orientations and distances from the individual detectors to simulate potential contamination.

The inspectors verified that radiation detection sensitivities were consistent with NRC guidance in IE Circular 81-07 Control of Radioactively Contaminated Material, May 14, 1981, and IE Information Notice 85-92. Documents reviewed are listed in the

.

The inspectors completed 10 of the required 10 samples.

Problem Identification and Resolution. Selected licensee CAP documents including CRs and audits associated with REMP activities, meteorological monitoring activities and unrestricted release of materials from the RCA were reviewed and discussed with responsible licensee representatives. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve selected issues in accordance with licensee procedure NMP-GM-002-GL02. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed a sample of the licensee submittals for the performance indicators (PIs) listed below to verify the accuracy of the data reported. The PI definitions and the guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2 and licensee procedure 00AC-REG-005-0S, Preparation And Reporting Of NRC PI Data, were used to verify procedure and reporting requirements were met.

Initiating Events Cornerstone

  • Unplanned Power Changes The inspectors reviewed raw PI data collected since October 2004 for each of the indicators identified and compared graphical representations from the most recent PI report to the raw data to verify the data was included in the report. The inspectors also examined a sampling of operations logs and procedures to verify the PI data was appropriately captured for inclusion into the PI report, and the individual PIs were calculated correctly.

Occupational Radiation Safety Cornerstone

  • Occupational Exposure Control Effectiveness For the period January 2005 through June 2006, the inspectors assessed CAP records to determine whether HRA, VHRA, or unintended radiation exposures, resulting in TS or 10 CFR 20 non-conformances, had occurred. In addition, the inspectors reviewed selected personnel contamination event data, internal dose assessment results, and electronic dosimeter alarms associated with dose rates exceeding one rem per hour and cumulative dose rates exceeding established set-points from January 2005 through June 2006. Documents reviewed are listed in the Attachment.

Public Radiation Safety Cornerstone

  • RETS/ODCM Radiological Effluents Occurrence The inspectors reviewed data for CY 2005. The inspectors also interviewed licensee personnel that were responsible for collecting and reporting the PI data. In addition, licensee procedural guidance for classifying and reporting PI events was evaluated.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Screening of Corrective Action Items

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.

.2 Annual Sample Review

a. Inspection Scope

The inspectors performed a detailed review of the following four CRs to verify the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CR against the licensees CAP as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

  • Foreign Material in the Iso-Phase Bus duct resulted in a generator trip
  • Failure to establish complete contingency plans after the PASS was removed from Technical Specifications

b. Findings and Observations

Introduction.

An NRC-identified NCV of 10 CFR 50.73 (a)(2)(i)(B) was identified for failure to report conditions prohibited by plant TS. The inspectors determined that, during the most recent operating cycle for both Units 1 and 2, several main steam SRVs exceeded the lift setting tolerance in TS.

Description.

During a review of the as-found lift setpoints of the SRVs removed from Unit 2 during the spring 2005 outage, the inspectors noted 5 of the 11 SRVs exceeded the maximum allowed lift setting of 1184.5 psig, ranging from 1186 psig to 1251 psig.

An additional review was performed of the as-found lift settings for the SRVs removed from Unit 1 during the spring 2006 outage. The inspectors noted 3 of the 11 SRVs exceeded the maximum allowed lift setting of 1184.5 psig, ranging from 1185 psig to 1271 psig. The inspectors reviewed TS 3.4.3 and SR 3.4.3.1 and determined the safety function is demonstrated as operable by an as-found lift setpoint of 1150 psig + 34.5 psig. A review of the TS Bases for TS 3.4.3 noted The ASME Boiler and Pressure Vessel Code requires the reactor pressure vessel be protected from overpressure during upset conditions by self-actuated safety valves. (emphasis added). NUREG 1022 states the existence of similar discrepancies in multiple valves is an indication that the discrepancies may well have arisen over a period of time and the failure mode should be evaluated to make this determination. If so, the condition existed during plant operation and the event reportable under 50.73(a)(2)(i)(B) Any operation or condition prohibited by the plants Technical Specifications. The inspectors questioned the licensee regarding the failure mechanism and reporting requirements. The failure mechanism was attributed to corrosion-induced bonding of the pilot valve disc and seat.

The decision to stop reporting as-found SRV lift setpoint drift as documented in Licensee Event Report (LER) 05000321-93-002 was based, in error, on an improvement in SRV reliability due to the installation of pressure actuating switches and not compliance with TS.

Analysis.

This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact the NRCs ability to perform its regulatory function. This finding was determined to be a SL IV violation based on Supplement I of the NRC Enforcement Policy.

Enforcement.

10 CFR 50.73 (a)(2)(i)(B) requires that any condition or operation prohibited by TS be reported in an LER. Contrary to the above, the licensee failed to report multiple cases where SRV as-found testing results were greater than the 1150 psig + 34.5 psig permitted by TS. However, because the failure to report is a SL IV violation and has been entered into the licensees CAP as CR 2006110200, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000321,366/2006004-01, Failure to Report Safety Relief Valve Test Results Outside Technical Specification Limits.

No other findings of significance were identified. The root cause performed for the generator trip caused by foreign material intrusion was comprehensive and included a review of seven foreign material intrusion events. The root cause performed for the omission of required chemistry sampling guidance when the PASS was removed from TS was factual and accurate. The root cause identified weakness in the TS change process and the proposed programmatic changes appeared adequate. The root cause performed as a result of an operator inadvertently securing the remaining running reactor feed pump was detailed and factual. The corrective actions appropriately focused on human performance and error prevention.

4OA3 Event Followup

a. Inspection Scope

For the non-routine event described below, the inspectors reviewed operator logs, plant computer data, and strip charts to determine what occurred and how the operators responded, and to determine if the response was in accordance with plant procedures.

Documents reviewed are listed in the Attachment.

  • On July 30, the inspectors observed the site response to the runback of the 1A Recirculation Pump caused by a failed relay in the control circuit. Power momentarily traversed into the Immediate Exit region of the Power/Flow Map and operators reduced power to exit the area.

b. Findings

No findings of significance were identified.

4OA5 Other Activities

.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI)

a. Inspection Scope

The inspectors reviewed selected ISFSI operations to verify that the licensee performed ISFSI activities safely and in compliance with approved procedures. These reviews were conducted in accordance with NRC Inspection Procedures 60855 and 60855.1.

The inspectors reviewed records to verify that the licensee had properly identified the parameters of each fuel assembly loaded, and that a physical inventory had been performed on all spent fuel in the ISFSI on a frequency of at least every 12 months.

The inspectors also reviewed the TS to verify that the fuel placed in these casks met the requirements. The inspectors walked down the ISFSI pads to assess the material condition of the casks, the installation of security equipment, and the performance of the monitoring systems. The inspectors also reviewed ISFSI document control practices to verify that any changes to the required ISFSI procedures were performed in accordance with guidelines established in local procedures and 10CFR72.48. Documents reviewed are listed in the Attachment.

  • Licensing Document Change Request 2006-004DC, Evaluation of Changes to the 2006 Dry Storage Equipment and Corresponding Changes to the Hatch 10 CFR 72.212 Report

b. Findings

No findings of significance were identified.

.2 ISFSI Radiological Controls

a. Inspection Scope

The inspectors conducted independent gamma surveys of the ISFSI facility and compared the results to previous quarterly surveys. The inspectors also observed and evaluated implementation of radiological controls, including RWPs, postings and TLD placement, and discussed the controls with an HPT and HP supervisory staff.

Radiological controls for loading Hi-Star 100 ISFSI casks were also reviewed and discussed. Radiological control activities for ISFSI areas were evaluated against 10 CFR Part 20, 10 CFR Part 72, and applicable licensee procedures. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On October 13, 2006, the inspectors presented the inspection results to Mr. Dennis Madison and the other members of his staff who acknowledged the observations. The inspectors confirmed proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

D. Madison, General Manager - Nuclear Plant
M. Ajluni, Assistant General Manager - Plant Support
S. Douglas, Assistant General Manager - Plant Operations
B. Goodwin, Engineering Manager
G. Johnson, Operations Manager
J. Lewis, Training and Emergency Preparedness Manager
J. Thompson, Nuclear Security Manager
R. Varnadore, Maintenance Manager
J. Dixon, Health Physics Manager

LIST OF ITEMS

OPENED AND CLOSED

Opened and Closed

05000321,366/2006004-01 NCV Failure to Report Safety Relief Valve Test Results Outside Technical Specification Limits. (Section 4OA2.2)

LIST OF DOCUMENTS REVIEWED

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