IR 05000331/2002003
| ML021060125 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 04/15/2002 |
| From: | Burgess B NRC/RGN-III/DRP/RPB2 |
| To: | Vanmiddlesworth G Nuclear Management Co |
| References | |
| IR-02-003 | |
| Download: ML021060125 (34) | |
Text
April 15, 2002
SUBJECT:
DUANE ARNOLD ENERGY CENTER NRC INSPECTION REPORT 50-331/02-03(DRP)
Dear Mr. Van Middlesworth:
On March 30, 2002, the NRC completed an inspection at your Duane Arnold Energy Center.
The enclosed report documents the inspection findings which were discussed on April 2, 2002, with Mr. R. Anderson and other members of your staff.
This inspection examined activities conducted under your license as they relate to reactor 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.
No findings of significance were identified.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
Sincerely, Original signed by Bruce L. Burgess Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Docket No. 50-331 License No. DPR-49
Enclosure:
Inspection Report 50-331/02-03(DRP)
See Attached Distribution
DOCUMENT NAME: G:\\duan\\ML021060125.wpd To receive a copy of this document, indicate in the box "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII NAME GWright/trn BBurgess DATE 04/09/02 04/15/02 OFFICIAL RECORD COPY
G. Van Middlesworth-2-
REGION III==
Docket No:
50-331 License No:
DPR-49 Report No:
50-331/02-03(DRP)
Licensee:
Alliant, IES Utilities Inc.
Facility:
Duane Arnold Energy Center Location:
3277 DAEC Road Palo, Iowa 52324-9785 Dates:
February 15 through March 30, 2002 Inspectors:
P. Prescott, Senior Resident Inspector M. Kurth, Resident Inspector T. Ploski, Senior Emergency Preparedness Analyst R. Jickling, Emergency Preparedness Analyst R. Schmitt, Radiation Specialist G. Wright, Project Engineer Approved by:
Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects
SUMMARY OF FINDINGS IR 05000331-02-03(DRP), on 02/15-03/30/2002, IES Utilities, Inc., Duane Arnold Energy Center. Routine safety inspection.
This report covers a 6-week routine inspection. The inspection was conducted by resident inspectors, region-based emergency preparedness specialists, and a radiation protection specialist. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609 Significance Determination Process (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRC/OVERSIGHT/index.html. Findings for which the SDP does not apply are indicated by No Color or by the severity level of the applicable violations.
A.
Inspector Identified Findings No findings of significance were identified.
B.
Licensee Identified Findings No findings of significance were identified.
Report Details Summary of Plant Status The plant was operated at the reduced power level of 1770 megawatts thermal (MWth) at the beginning of the inspection period due to oscillations on the B feedwater regulating valve. On February 17, 2002, drywell leakage surpassed 1.0 gallons per minute (GPM). Chemical analysis of a drywell floor drain sample indicated the leakage source was well water, used in the drywell air coolers. On February 26, leakage dropped and held steady at approximately 0.8-0.9 GPM through the end of the month. On March 3, at 12:00 p.m., an orderly scheduled shutdown was commenced to identify and repair the source of the drywell leakage. On March 4, at 2:05 p.m., the generator was taken offline and at 3:40 p.m., a reactor scram was inserted. Following completion of the repairs, the reactor was taken critical on March 8, at 1:42 p.m. The generator was synchronized to the grid on March 9, at 2:07 p.m. During the outage, a modification was performed on the feedwater regulating valve to permit full power operation at 1790 MWth. Full power was achieved March 11, at 1:19 p.m. The plant was operated at or near full power for the remainder of the period.
1.
REACTOR SAFETY Cornerstones: Initiating events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness 1R04 Equipment Alignment (71111.04)
a.
Inspection Scope The inspectors performed a partial walkdown of the following redundant equipment trains to verify operability and proper equipment lineup while the counterpart train was disabled due to planned maintenance. These systems were selected due to the increase in core damage frequency caused by rendering one train of emergency core cooling system (ECCS) out-of-service for maintenance.
- High Pressure Coolant Injection System (HPCI)
Reactor Core Isolation Cooling (RCIC)
The inspectors verified the position of critical redundant equipment and looked for any discrepancies between the existing equipment lineup and the required lineup.
b.
Findings No findings of significance were identified.
1R05 Fire Protection (71111.05)
a.
Inspection Scope The inspectors walked down the following risk significant areas looking for any fire protection issues. The inspectors selected areas containing systems, structures, or components that the licensee identified as important to reactor safety.
- Reactor Building Torus Area and North Corner Rooms
Reactor Building South Corner Rooms
Reactor Building HPCI, RCIC, and Radwaste Tank Rooms The inspectors reviewed the control of transient combustibles and ignition sources, fire detection equipment, manual suppression capabilities, passive suppression capabilities, automatic suppression capabilities, and barriers to fire propagation.
b.
Findings No findings of significance were identified.
1R06 Flood Protection Measures (71111.06)
a.
Inspection Scope The inspectors reviewed the licensee's flooding mitigation plans and equipment to determine consistency with design requirements and the risk analysis assumptions.
Walkdowns were conducted of the interior and exterior walls of the pump house, reactor building, turbine building, and the low level radiation waste processing and storage facility.
b.
Findings No findings of significance were identified.
1R11 Licensed Operator Requalification Program (71111.11)
a.
Inspection Scope The inspectors observed the licensed operator training and evaluation conducted in accordance with requalification scenario guide, SEG [Simulator Evaluation Guide]
2002C2-3, Revision 0. The exercise was conducted on March 19, 2002.
The exercise scenario challenged operators to respond to a loss of river water supply and loss of the emergency service water and residual heat removal systems. Also, the crew responded to a security threat. During the course of the scenario, abnormal and emergency operating procedures were used and event classification opportunities occurred. Areas observed by the inspectors included: clarity and formality of
communications, timeliness of actions, prioritization of activities, procedural adequacy and implementation, control board manipulations, managerial oversight, emergency plan execution, and group dynamics. In addition, event classification actions were observed.
The classifications were not included as part of the performance indicator data for this scenario.
b.
Findings No findings of significance were identified.
1R12 Maintenance Rule Implementation (71111.12)
a.
Inspection Scope The inspectors reviewed the licensees implementation of the Maintenance Rule (10 CFR 50.65) to ensure rule requirements were met for the selected systems.
The following systems were selected based on being designated as risk significant under the Maintenance Rule, or being in the increased monitoring (Maintenance Rule category a(1)) group:
High pressure coolant injection system
Instrument air system
Emergency service water system The inspectors verified the licensee's categorization of specific issues, including evaluation of the performance criteria. The inspectors reviewed the licensee's implementation of the maintenance rule requirements, including a review of scoping, goal-setting, and performance monitoring; short-term and long-term corrective actions; functional failure determinations associated with the condition reports reviewed; and current equipment performance status.
b.
Findings No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a.
Inspection Scope The inspectors reviewed and observed emergent work, preventive maintenance, or planning for risk significant maintenance activities. The inspectors observed maintenance or planning for the following activities or risk significant systems undergoing scheduled or emergent maintenance.
- Weekly Scheduling and Planning Meetings
Forced Outage Planning and Emergent Work Review
Specifically, the inspectors reviewed the risk assessment of scheduled maintenance activities associated with work weeks 10 and 12. Work week 10 included work for the forced outage to repair the drywell coolers. Work week 12 involved work on the A control room standby filter unit.
The inspectors also reviewed the licensee's evaluation of plant risk, risk management, scheduling, and configuration control for these activities in coordination with other scheduled risk significant work. The inspectors verified that the licensee's control of activities considered assessment of baseline and cumulative risk, management of plant configuration, control of maintenance, and external impacts on risk. In-plant activities were reviewed to ensure that the risk assessment of maintenance or emergent work was complete and adequate, and that the assessment included an evaluation of external factors. Additionally, the inspectors verified that the licensee entered the appropriate risk category for the evolutions.
b.
Findings No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
a.
Inspection Scope The inspectors reviewed the technical adequacy of the following operability evaluations to determine the impact on TS, the significance of the evaluations, and to ensure that adequate justifications were documented.
- Action Request (AR) 29756, 1LUPSB (Safe Shutdown/SBO [Station Black-Out]
MCR [Main Control Room] Lighting UPS [Uninterruptible Power Supply]) Battery Posts Show Signs of Degradation
AR 28778, MO1933 Exhibits Increased Running Load at the End of the Closing Stroke and at the Beginning of the Opening Stroke
AR 30204, Diesel Fuel Oil Transfer Pump Motor Control Center Power Supply to 1G31 Fuel Oil Makeup Pump Wiring is Incorrect
AR 30414, Can the Residual Heat Removal Pump Seals (i.e., 1P229A, 1P229B, 1P229C and 1P229D) Operate Under Accident Conditions Without Seal Cooling Operability evaluations were selected based upon the relationship of the safety-related system, structure, or component to risk.
b.
Findings No findings of significance were identified.
1R16 Operator Workarounds (OWAs) (71111.16)
a.
Inspection Scope The inspectors reviewed OWA 27260, Unplanned Capability Loss Factor (UPCLF)
Review - Drywell Cooling. The inspectors reviewed the workarounds potential to impact the operators ability to cool the drywell.
The inspectors reviewed the workaround for impact on the reliability, availability, and potential for improper operation of the system. Additionally, a review was conducted to determine if the workaround could increase the possibility of an initiating event, affect multiple mitigating systems, or impact the operators ability to respond to accidents or transients.
b.
Findings No findings of significance were identified.
1R17 Permanent Plant Modifications (71111.17)
a.
Inspection Scope The inspectors reviewed the following modification to verify that the design basis, licensing basis, and performance capability of risk significant systems were not degraded by the installation of the modification. The inspectors also verified that the modification did not place the plant in an unsafe configuration.
- Engineered Maintenance Action (EMA) A51490, Replace TIS4443 Main Steam Line A Steam Tunnel High Temperature for Primary Containment Isolation System Channel A1" The inspectors considered the design adequacy of the modification by performing a review, or partial review, of the modifications impact on plant electrical requirements, material requirements and replacement components, response time, control signals, equipment protection, operation, failure modes, and other related process requirements.
b.
Findings No findings of significance were identified.
1R19 Post-Maintenance Testing (PMT) (71111.19)
a.
Inspection Scope The inspectors selected the following post-maintenance activities for review. Activities were selected based upon the structure, system, or component's ability to impact risk.
- Observed surveillance test procedure (STP) 3.5.3-02, RCIC System Operability Test, Revision 11, following a RCIC system planned maintenance outage.
- Observed PMT and reviewed corrective work order (CWO) A58840, Calibrate and Develop Stroke Time Versus Volume Booster Setting Curve [CV1621-0, B Feedwater Regulating Valve]
Observed mock-up testing and reviewed unidentified drywell leakage data following completion of CWO A58115, Repair the Leaking 1VCC005B Drywell Cooler
Reviewed data from preventive work order (PWO) 1118453, Complete Mechanical Inspection of 1G021 B Emergency Diesel Generator The inspectors verified by witnessing the test or reviewing the test data that post-maintenance testing activities were adequate for the above maintenance activities.
The inspectors reviews included, but were not limited to, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use and compliance, control of temporary modifications or jumpers required for test performance, documentation of test data, TS applicability, system restoration, and evaluation of test data. Also, the inspectors verified that maintenance and post-maintenance testing activities adequately ensured that the equipment met the licensing basis, TS, and USAR design requirements.
b.
Findings No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a.
Inspection Scope The inspectors selected the following surveillance test activities for review. Activities were selected based upon risk significance and the potential risk impact from an unidentified deficiency or performance degradation that a system, structure, or component could impose on the unit if the condition were left unresolved.
- STP 3.3.6.1-10, Reactor Lo Lo Water Level (ATWS [Anticipated Transient Without Scram]-RPT [Reactor Protection Trip]/ARI [All Rods In] Trip RWCU
[Reactor Water Clean-Up] Isolation) and Lo Lo Water Level (Main Steam Line Isolation Trip) Channel Calibration, Revision 5
STP 3.3.1.2-01, Source Range Monitor Channel Functional Test, Revision 3
STP 3.5.1-05, HPCI System Operability Test, Revision 15 The inspectors observed the performance of surveillance testing activities, including reviews for preconditioning, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use, control of temporary modifications or jumpers required for test performance, documentation of test data, TS applicability, impact of testing relative to performance indicator reporting, and evaluation of test data.
b.
Findings No findings of significance were identified.
Cornerstone: Emergency Preparedness 1EP2 Alert and Notification System (ANS) Testing (71114.02)
a.
Inspection Scope The inspectors discussed with Emergency Preparedness (EP) staff the design, equipment, and periodic testing of the public ANS for the Duane Arnold reactor facility emergency planning zone to verify that the system was properly tested and maintained.
The inspectors also reviewed procedures and records for an 18-month period ending September 2001, related to ANS testing, annual preventive maintenance, and non-scheduled maintenance. The inspectors reviewed the licensees criteria for determining whether each model of siren installed in the emergency planning zone would perform as expected if fully activated. Records used to document and trend component failures for each model of installed siren were also reviewed to ensure that corrective actions were taken for test failures or system anomalies.
b.
Findings No findings of significance were identified.
1EP3 Emergency Response Organization (ERO) Augmentation Testing (71114.03)
a.
Inspection Scope The inspectors reviewed the licensees ERO augmentation testing to verify that the licensee maintained and tested its ability to staff the ERO during an emergency in a timely manner. Specifically, the inspectors reviewed semi-annual, off-hours staff augmentation drill procedures, related September 12 and 26, 2000, April 10, 2001, and August 28, 2001 drill records, primary and backup provisions for off-hours notification of the Duane Arnold reactor facility emergency responders, and the current ERO rosters for Duane Arnold. The inspectors reviewed and discussed with the EP staff the facilitys provisions for maintaining ERO call out lists.
b.
Findings No findings of significance were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a.
Inspection Scope The inspectors reviewed Revision 22 to Section B and Revision 21 to Section F of the emergency plan to determine whether these revisions reduced the effectiveness of the licensees emergency planning, pending onsite inspection of the implementation of these revisions.
b.
Findings No findings of significance were identified.
1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)
a.
Inspection Scope The inspectors reviewed the Nuclear Oversight staffs 2000 and 2001 audits to ensure that these audits complied with the requirements of 10 CFR 50.54(t) and that the licensee adequately identified and corrected deficiencies. The inspectors also reviewed the EP staffs self-assessments and critiques to evaluate the EP staffs efforts to identify and correct weaknesses and deficiencies. Additionally, the inspectors reviewed action requests related to the facilitys EP program to determine whether corrective actions were completed.
b.
Findings No findings of significance were identified.
2.
RADIATION SAFETY Cornerstone: Occupational Radiation Safety 2OS1 Access Control to Radiologically Significant Areas (71121.01)
.1 Plant Walkdowns, Radiological Boundary Verifications, and Radiation Work Permit Reviews a.
Inspection Scope The inspector conducted walkdowns of the radiologically protected area to verify the adequacy of radiological area boundaries and postings. Specifically, the inspector walked down radiologically significant work area boundaries (i.e., radiation, high and locked high radiation areas) in the Reactor Building, Radwaste Building, Spent Fuel Pool area, and the Turbine Building. The inspector performed confirmatory radiation surveys in selected portions of these areas to verify that these areas were properly posted and controlled in accordance with 10 CFR Part 20, licensee procedures, and Technical Specifications. The inspector also examined the radiological conditions of work areas
within those radiation and high radiation areas, to assess contamination controls.
Additionally, the inspector reviewed radiation work permits (RWPs) for general tours, access to high radiation /locked high radiation areas (HRA/LHRAs), and for the removal of the shielded lid on a re-useable steel shipping liner (and its pre-use inspection), to verify that work instructions and controls had been adequately specified and that electronic dosimeter set points were in conformity with survey indications.
b.
Findings No findings of significance were identified.
.2 Job-In-Progress Reviews, Observations of Radiation Worker Performance, and Radiation Protection Technician Proficiency a.
Inspection Scope The inspector observed the following radiological work activity performed during the inspection and evaluated the licensees use of radiological controls:
Removal of a shielded lid and pre-use inspection of a re-useable steel liner
The inspector attended the pre-job briefing for the work evolution, reviewed the radiological job requirements for the activity, and assessed job performance with respect to those requirements. The inspector reviewed survey records, including radiation, contamination, and airborne surveys to verify that appropriate radiological controls were effectively utilized. The inspector also reviewed in-process surveys and applicable postings and barricades to verify their accuracy. The inspector observed radiation protection technician and worker performance during the work evolution at the job site to verify that the technicians and workers were aware of the significance of the radiological conditions in their workplace, RWP controls/limits, and that they were performing adequately, given the level of radiological hazards present and the level of their training.
b.
Findings No findings of significance were identified.
.3 Identification and Resolution of Problems a.
Inspection Scope The inspector reviewed licensee Action Requests (ARs) written since the last assessment (December 2001) to the date of the current assessment, which focused on access control to radiologically significant areas (i.e., problems concerning activities in HRAs, radiation protection technicians performance, and radiation worker practices).
The inspector reviewed these documents to verify the licensees ability to identify repetitive problems, contributing causes, the extent of conditions, and then implement other corrective actions in order to achieve lasting results.
b.
Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety (PS)
2PS2 Radioactive Material Processing and Transportation (71122.02)
.1 Walk-Downs of Radioactive Waste Systems a.
Inspection Scope The inspector performed walkdowns of the liquid and solid radioactive waste systems to assess their material condition and operability and to verify that radiological hazards were adequately posted and controlled in accordance with 10 CFR Part 20 and the licensees Technical Specifications. The inspector also discussed the current operation of the systems with a member of the radioactive waste operations crew. Specifically, the inspector reviewed the condition of radioactive waste system components located in the following areas:
Abandoned evaporator tank room;
Abandoned Radwaste centrifuge area;
Abandoned Radwaste hopper room;
Abandoned Radwaste lanes/capper area;
Condensate backwash receiving tank room;
Shipping bay and de-watering processing area;
Solid radioactive waste handling, storage, and processing areas;
Spent resin tank room;
Waste sludge tank room; and
Waste collector tank room.
The inspector compared the operations of the liquid/solid radioactive waste systems to the descriptions in the Updated Final Safety Analysis Report and the licensees process control program. In the case of abandoned equipment (e.g., partially disassembled centrifuge system and evaporators), the inspector reviewed the administrative and physical controls to verify that the equipment would not contribute to an unmonitored release path and would not inadvertently affect operating systems. During this inspection, the licensee was not conducting waste processing.
b.
Findings
No findings of significance were identified.
.2 Waste Characterization and Classification a.
Inspection Scope The inspector reviewed the licensees method and procedures for determining the classification of radioactive waste shipments, including the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). Specifically, the inspector reviewed the licensees calender year (CY) Summer 2000 radio-chemical analysis results for condensate resin and dry active waste (DAW). The inspector reviewed the report to verify that the licensees scaling factors were accurately determined such that waste shipments were classified in accordance with the requirements contained in 10 CFR Part 61 and the licensees process control program. The inspector also reviewed the methodologies for waste concentration averaging to determine if they contained provisions for representative samples of the waste product for the purposes of waste classification. These reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20.
Additionally, the inspector reviewed the licensees processes employed to ensure that changes in operating parameters (i.e., a recent power upgrade), which may result in changes to the waste stream composition, are identified between the annual or biennial scaling factor updates.
b.
Findings No findings of significance were identified.
.3 Ongoing Shipment Preparation and Radioactive Waste Processing Activities a.
Inspection Scope The inspector observed an ongoing shipment of effluent release samples (Limited Quantity) to ensure that the shipping activities were performed in accordance with the requirements of 49 CFR Parts 172 and 173. Specifically, the inspector reviewed shipping calculations and paperwork, performed independent radiological surveys, and observed the packaging of the shipment, before final transfer to the carrier. Since direct observations of shipping activities were limited, the inspector examined the training program provided to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities to assess the licensees compliance with 49 CFR Part 172, Subpart H requirements. Specifically, the inspector reviewed the lesson plans, student handouts, and course completion documentation for licensee and vendor-provided courses to ensure that personnel (i.e., warehouse shipping/receiving, Radwaste operators, radiation protection technicians, and managers) had adequately completed both the general awareness/safety training and function specific training applicable for their individual job functions. Additionally, the inspector reviewed training records for subsequent recurrent/refresher training to verify that applicable personnel had completed the training within the last three years.
b.
Findings
No findings of significance were identified.
.4 Shipping Records a.
Inspection Scope The inspector reviewed a selection of non-excepted package shipments completed during CY(s) 2000 - 2001 to verify compliance with NRC and Department of Transportation (DOT) requirements (i.e., 10 CFR Parts 20 and 71; 49 CFR Parts 172 and 173). Specifically, the inspector reviewed the following radioactive materials/waste shipment records:
Radioactive Materials
RSR 01-35, Refueling/Outage Equipment (SCO II), May 24, 2001
RSR 01-60, Fuel Scrapings and CAV samples (Rad Mat NOS), October 3, 2000 Radioactive Wastes
RSR 00-017, Oil, DAW, Sources, Sandblast grit, and Paint chips (LSA II, Class A), October 27, 2000
RSR 00-21, Condensate Resin (LSA II, Class A), December 14, 2000
RSR 01-19, Low Pressure MSR bundle (SCO II, Class A), April 30, 2001
RSR 01-55, DAW (Hot Trash) (LSA II, Class A), October 2, 2001
RSR 01-64, Condensate Resin (>A LSA II, Class A), December 11, 2001 The inspector also interviewed an Operations Shift Manager (i.e., who would be responsible for answering the licensees emergency response 24-hour telephone number) to verify that the individual had adequate knowledge concerning the shipment, emergency precautions, and incident mitigation information or that the individual had immediate access to a person who possessed such knowledge.
b.
Findings No findings of significance were identified.
.5 Problem Identification and Resolution a.
Inspection Scope The inspector reviewed self-assessments, audits, and action requests (AR) completed during the previous 18 months which concerned the areas of radioactive waste processing and radioactive waste/material shipping. The inspector reviewed these documents to assess the licensees ability to identify repetitive problems, contributing causes, the extent of conditions, and corrective actions which will achieve lasting results.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES 4OA1 Performance Indicator Verification (71151)
Cornerstone: Mitigating Systems
.1 Safety System Unavailability a.
Inspection Scope The inspectors verified the accuracy and completeness of the Safety System Unavailability - RCIC system performance indicator data submitted by the licensee from August 1, 2001 through December 31, 2001. The inspectors reviewed data reported to the NRC since the last verification. The review was accomplished, in part, through evaluation of the TS requirements, plant records, procedural reviews, and reactor coolant sample data.
b.
Findings No findings of significance were identified.
.2 Emergency Preparedness a.
Inspection Scope The inspectors verified that the licensee had accurately reported these indicators:
ANS, ERO Drill Participation, and Drill and Exercise Performance (DEP) for the EP cornerstone. Specifically, the inspectors reviewed the licensees PI records, data reported to the NRC, and action requests for the period April 2000 through September 2001. Records of relevant Control Room Simulator training sessions, periodic ANS tests, and excerpts of drill and exercise scenario and evaluations were also reviewed to identify any occurrences that were not identified by the licensee and entered into the station corrective action program.
b.
Findings No findings of significance were identified.
.3 Radiation Protection a.
Inspection Scope The inspector reviewed the licensees assessment of the performance indicator (PI) for the Reactor Safety, Barrier Integrity Cornerstone, Reactor Coolant System (RCS)
Specific Activity element. No reportable elements were identified by the licensee for the 1st, 2nd, 3rd, and 4th quarters of 2001. The inspector compared the licensees data with calender year (CY) 2001 ARs to verify that there were no occurrences concerning the Barrier Integrity cornerstone, RCS Specific Activity element. The inspector also observed licensee staff (i.e. chemistry technicians) collecting RCS samples to verify that the technicians had complied with the applicable procedures during the collection and processing of the samples.
b.
Findings No findings of significance were identified.
4OA6 Meeting Exit Meeting The inspectors presented the inspection results to Mr. R. Anderson and other members of licensee management on April 2, 2002. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
Interim exits related to the Emergency Preparedness Program, Access Control to Radiologically Significant Areas, Radioactive Material Processing and Transportation, and associated performance indicators inspections were conducted on November 2, 2001 and March 1, 2002 with Mr. G. Van Middlesworth and Mr. R. Anderson respectively. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
KEY POINTS OF CONTACT Licensee D. Allison, Radioactive Waste Shipping Coordinator R. Anderson, Plant Manager B. Bernier, System Engineer Supervisor J. Bjorseth, Manager, Engineering D. Brigl, Long Term Program Engineer R. Brown, Nuclear Oversight Manager E. Christopher, Program Engineer D. Curtland, Site Support Manager K. Dunlap, Emergency Preparedness Planner J. Ertman, Team Leader-Engineer T. Evans, Operations Manager L. Gibney, Emergency Preparedness Planner H. Giorgio, Manager, Radiation Protection A. Johnson, Operations Training Supervisor R. Johnson, Emergency Preparedness Scenario Developer D. Johnson, Emergency Preparedness Specialist J. Karrick, Licensing B. Kindred, Security Manager L. Kriege, Chemistry Supervisor J. Lohman, Communications Manager S. McVay, System Engineer S. Nelson, Health Physics Supervisor J. Newman, Radiological Engineering Supervisor K. Putnam, Licensing Manager B. Richmond, Radioactive Waste Supervisor A. Roderick, Principal Mechanical Engineer W. Simmons, Maintenance Superintendent P. Sullivan, Emergency Planning Manager R. Titus, Emergency Preparedness Planner G. Van Middlesworth, Site Vice-President Nuclear C. Vogeler, Emergency Preparedness Specialist G. Whittier, RHR System Engineer K. Williams, Senior Emergency Planning Specialist NRC B. Burgess, Chief, Branch 2, DRP M. Kurth, Resident Inspector P. Prescott, Senior Resident Inspector R. Reynolds, Deputy Division Director, DRP
ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None
LIST OF ACRONYMS USED ADAMS NRCs Document System AFP Area Fire Plan ALARA As Low As Reasonably Achievable ANS Alert and Notification System AR Action Request ARI All Rods In ATWS Anticipated Transient Without Scram CAV Crack Arrest Verification CFR Code of Federal Regulations CWO Corrective Work Order CY Calender Year DAEC Duane Arnold Energy Center DAW Dry Active Waste DEP Drill and Exercise Performance DOT Department of Transportation DRP Division of Reactor Projects DRS Division of Reactor Safety ECCS Emergency Core Cooling System EMA Engineered Maintenance Action EP Emergency Preparedness ERO Emergency Response Organization HPCI High Pressure Coolant Injection HRA High Radiation Area LHRA Locked High Radiation Area LSA Low Specific Activity MCR Main Control Room MSR Main Steam Re-Heat MWt Megawatt Thermal NOS Not Otherwise Specified NRC Nuclear Regulatory Commission OI Operating Instruction OWA Operator Work-Around P&IDs Piping and Instrumentation Drawings PARS Public Availability Records PI Performance Indicator PMT Post Maintenance Test PS Public Radiation Safety PWO Preventive Work Order Rad Mat Radioactive Material Radwaste Radioactive Waste RCIC Reactor Core Isolation Cooling RCS Reactor Coolant System RFO 17 Refueling Outage 17 ROP Reactor Oversight Process RP Radiation Protection RPT Reactor Protection Trip RWCU Reactor Water Clean-Up
RWP Radiation Work Permit SBO Station Black-Out SCO Surface Contaminated Object SDP Significance Determination Process SSCs Structure, System, or Components STP Surveillance Test Procedure TEDE Total Effective Dose Equivalent TS Technical Specification UFSAR Updated Final Safety Analysis Report UPCLF Unplanned Capacity Loss Factor
LIST OF DOCUMENTS REVIEWED The following documents were selected and reviewed by the inspectors to accomplish the objectives and scope of the inspection and to support any findings.
1R04 Equipment Alignment Operating Instruction (OI)
152 High Pressure Coolant Injection System Revision 51 P&ID (Piping &
Instrumentation Diagram) M-122 HPCI (Steam Side)
Revision 52 P& ID M-123 HPCI (Water Side)
Revision 37 OI 150 Reactor Core Isolation Cooling System Revision 41 P&ID M-124 RCIC (Steam Side)
Revision 45 P&ID M-125 RCIC (Water Side)
Revision 31 1R05 Fire Protection Area Fire Plan (AFP)-3 Reactor Building HPCI, RCIC and Radwaste Tank Rooms Revision 22 AFP-2 Reactor Building South Corner Rooms Revision22 AFP-1 Reactor Building Torus Area and North Corner Rooms Revision22 Fire Plan -
Volume II Fire Brigade Organization Revision 32 1R06 Flood Protection Measures UFSAR 9.2.3.5.2 Emergency Service Water System Revision 14 Individual Plant Examination Section 3.3.6 Internal Flooding Analysis 1R11 Licensed Operator Requalification Program SEG 2002C2-3 Revision 0
1R12 Maintenance Rule Implementation Performance Criteria Basis Document High Pressure Coolant Injection Revision 2 Performance Criteria Basis Document Instrument Air System Revision 1 NG-97-1440, Expert Panel Meeting Minutes, Attachment 1 Data for Systems/Plant in Red - 10 CFR 50.65 (a)(1)
February 7, 2002 Performance Criteria Basis Document Essential Service Water Revision 1 1R13 Maintenance Risk Assessments and Emergent Work Control Planned Outage Look-Ahead Report February 27, 2002 Online Look-Ahead Agenda (Week 10)
February 28, 2002 Online Look-Ahead Agenda (Week 12)
March 14, 2002 1R15 Operability Evaluations AR 29756 1LUPSB (Safe Shutdown/SBO MCR Lighting UPS) Battery Posts Show Signs of Degradation February 01, 2002 AR 29562 1LUPSB YUSA Battery Cell Positive Strap Connection is Beginning to Heave on Cells A3 and B3. The B3 Strap may be Beginning to Crack January 17, 2002 AR 28778 MO1933 Exhibits Increased Running Load at the End of the Closing Stroke and at the Beginning of the Opening Stroke November 14, 2001 AR 30414 Can the Residual Heat Removal Pump Seals (i.e., 1P229A, 1P229B, 1P229C and 1P229D)
Operate Under Accident Conditions Without Seal Cooling March 28, 2002
1R16 Operator Workarounds AR 27260 Unplanned Capability Loss Factor (UCLF)
Review - Drywell Cooling September 28, 2001 1R17 Permanent Plant Modifications EMA Replace TIS4443 [Main Steam Line A Steam Tunnel High Temperature for Primary Containment Isolation System Channel A1 January 22, 2002 Safety Evaluation 99-011 Replace Existing Obsolete Chromalox Model 3000 Process Alarm Monitors with the Newer Chromalox Model 3421 Process Alarm Monitors April 13, 2001 Engineering Calculation CAL-239-406-018 Re-Evaluation of Masonry Walls, Wall C-406-18 October 4, 2001 USAR Change Request #01-012 Add Short Statement to the Effect that the MSL Area High Temperature Isolation will take Approximately 1.5 Seconds of the Available 5.5 Second Margin Assumed in the Accident Analysis April 11, 2001 1R19 Post-Maintenance Testing STP 3.5.3-02 RCIC System Operability Test Revision 11 A58840 Calibrate and Develop Stroke Time Versus Volume Booster Setting Curve [CV1621-0, B FRV]
March 4, 2002 A58839 Calibrate and Develop Stroke Time Versus Volume Booster Setting Curve [CV1579-0, A FRV]
A58115 Repair the Leaking 1VCC005B Drywell Cooler March 5, 2002 1118453 Complete Mechanical Inspection of 1G021 B Emergency Diesel Generator February 28, 2002 1R22 Surveillance Testing STP 3.3.6.1-10 Reactor Lo Lo Water Level (ATWS-RPT/ARI Trip RWCU Isolation) and Lo Lo Water Level (Main Steam Line Isolation Trip) Channel Calibration Revision 5
STP 3.3.1.2-01 Source Range Monitor Channel Functional Test Revision 3 STP 3.5.1-05 HPCI System Operability Test Revision 15 1EP2 Alert and Notification System (ANS) Testing EPDM 1013 Emergency ANS and Siren Sign Program Revision 0 Siren Trouble Shooting Guide Monthly Siren Test Polls, August - October 2001 Letter of Understanding Between the DAEC Electrical Shop and the EP Department September 16, 1999 Memorandum AR #21434, Siren Battery Failures December 28, 2000 Preliminary Report For AR #16385, Emergency Siren Inoperability Justification for the Addition of Addendum A to the FEMA-43/REP-10 Report An Offsite Emergency Plan Prompt ANS Addendum For The DAEC Revision 4A AR#20804 EP Siren 15J Reported as Inoperable July 18, 2000 AR#20829 DAEC Siren Operability Reports Show a Significant Negative Trend For June and July July 6, 2000 AR#20823 Need to Purchase a Portable Test Box for Whelen Emergency Siren System August 1, 2000 AR#20825 EP Siren Test Report for August 2000 August 3, 2000 AR#23299 Benton County Microwave to Sheriff and EOC Is Not Working December 13, 2000 1EP3 Emergency Response Organization (ERO) Augmentation Testing Memorandum Off-hours Callout October 3, 2000 Section C Emergency Plan Revision 20 Emergency Telephone Book April 10, 2001 Semi-Annual Off-hours Callout Test Results August 28, 2001 Semi-Annual Off-hours Callout Test Results
1EP4 Emergency Action Level and Emergency Plan Changes Section B DAEC Emergency Plan Revision 22 Section F DAEC Emergency Plan Revision 21 1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies ACP 114.5 Action Request System Revision 28 Section B DAEC Emergency Plan Revision 21 Memorandum Results of the 2000 ERO Survey April 3, 2000 ERO Training and Qualification Survey April 3, 2000 DAEC EP 71114 Assessment Report, August 27-31, 2001 Quality Assurance Quarterly Assessment Reports, Second - Fourth Quarters 2000 Nuclear Oversight Quarterly Assessment Reports, First - Second Quarters 2001 AR#20393 Action Items Generated During the EP Self-Assessment Have No Actions Taken June 22, 2000 AR#21433 Restore Rad Protection ERO Positions to 3 Deep October 3, 2000 AR#22207 Operations Training Comprehensive Self-evaluation Team Concern October 17, 2000 AR#22624 Year 2000 Evaluated Exercise: All Required Information Not Provided When Alert Declared October 18, 2000 AR#22641 Year 2000 Evaluated Exercise: EOF Was Misinformed of a Hard Pipe Release by the TSC October 19, 2000 AR#23739 Determine Method of Updating EP Call Out Board Listing Immediate Responders for Control Room January 24, 2001 AR#23861 Review EP Notification Per Recommendations February 6, 2001 AR#24234 Perform an Assessment of EP Program to Verify Conformance to NRC 71114 February 20, 2001 AR#24234 Create a Formal EP Siren Program Procedure February 20, 2001 AR#24485 Review of the Kewaunee Extent of Condition Root Cause Evaluation for Applicability to DAEC March 6, 2001
AR#26299 Requalification of ERO Responders From Security, Rad Pro, and Maintenance Exceeds Window May 30, 2001 AR#26558 The TSC ENS Communicator Position is One Deep June 26, 2001 AR#27668 Verify EPIP 1.1 Requires EAL Declaration Within 15 September 28, 2001 AR#27670 Benchmark To Determine How Numbers of Opportunities Are Measured for ERO PIs September 28, 2001 AR#27674 Evaluate Actions Necessary For 30-60 Minute Responders Who Cannot Respond in 30-60 Minutes September 28, 2001 AR#27676 Review EPDM 1008.1 to Determine if EALs Should Be Reviewed with Offsite Authorities September 28, 2001 AR#27678 Evaluate Need to Collect All Documentation During LOR for ERO Classification, Notification PIs September 28, 2001 AR#27786 Write a Procedure Encompassing All Areas of ERO Drill and Exercise Program Including Augmentation Drills and Documentation September 18, 2001 2OS1 Access Control to Radiologically Significant Areas Action Request items AR 29130 Revise High Radiation controls posting procedure, (i.e., response to Apparent Cause Evaluation of AR 29052 Failure to properly barricade access to HRA on turbine building roof)
December 11, 2001 AR 29280 Unauthorized entry into Torus (i.e. HRA), by Operations Technician, during a HPCI run, (Root Cause Report included).
December 19, 2001 AR 29409 Request for evaluation and establishment of expected dose rates for steam area entries, while at power.
January 4, 2002 AR 29867 Requirements for Procedure use and adherence clarified.
February 12, 2002 Procedures ACP 1411.22 Control of Access to Radiological Areas Revision 9 ACP 1411.23 Equipment and Material Controls in Radiological Areas Revision 9
Miscellaneou s Data IE01-P-01-100 (Vendor procedure)
ALARA lid installation/removal and inspection instruction Revision 0 RWP25 Radwaste specific HRA and LHRA jobs Revision 4 RWP 32 Routine NRC tours and surveillance Revision 12 02-445 Survey of re-useable steel liner, #02-R-002 February 28, 2002 ALARA Daily Focus, daily plant status briefing sheet February 26, 2002 DAEC weekly schedule for Health Physics Department February 25, 2002 2PS2 Radioactive Material Processing and Transportation Action Request items AR 22683 Green is Clean LSA box found with 25 mr/hr contact dose rate October 26, 2000 AR 24515 Unqualified truck driver arrived on-site to haul radioactive shipment March 3, 2001 AR 24526 Evaluate ownership and pre-job briefs for emergent Radwaste shipping March 8, 2001 AR 24682 Failure to properly survey in-coming radioactive shipment (i.e. truck), prior to off-loading.
March 24, 2001 AR 25121 Radioactive shipment package opened in warehouse, without Health Physics personnel authorization.
April 24, 2001 AR 29873 Contaminated radioactive shipment received at DAEC that require security search.
February 2, 2002 Procedures RWH 3402.21 IT-60 Evaporator bottom tank resin transfer and de-watering Revision 18 RWH 3403.1 Collection and control of miscellaneous liquid waste Revision 15 RWH 3404.1 General requirements for cask handling Revision 13 RWH 3404.4 Cask handling requirements for HN-190-2, HN-100 series 3, and 14-215 Revision 7
RWH 3404.5 Cask handling requirements for the 10-142B shipping cask Revision 5 RWH 3404.8 NLI-1/2 cask operating procedure Revision 0 RWH 3406.1 Waste classification and characterization Revision 5 RWH 3406.6 Characterizing radioactive material for transport Revision 5 RWH 3406.8 Packaging radioactive material for shipment Revision 4 RWH 3406.9 Marking and labeling for radioactive material and Radwaste packages Revision 5 RWH 3409.2 Sampling instructions and analysis of Radwaste streams Revision 7 RWH 3410.1 Process control program Revision 9 STP NS790401 Surveillance Test Procedure, Air filter Quarterly composite analysis Revision 2 STP NS790401 Surveillance Test Procedure, Results of air filter Quarterly composite analysis, February 27, 2002 Revision 2 TBD #8 Technical Basis Document, Surface contaminated object (SCO) classification and characterization.
Revision 0 00-003-R Radiological engineering calculation cover sheet-10CFR61 compliance data technical basis for DAEC, dry active waste (DAW)
Revision 0 00-004-R Radiological engineering calculation cover sheet-10CFR61 compliance data technical basis for DAEC, condensate resin Revision 0 Self -
Assessments 2001-003-1-029 Monitoring and control of plant effluents November 8, 2001 Section 6. Report A: Transfer, packaging, and storage of LLRW Section 6. Report I: Process control program
Miscellaneous Data ER-99-028 Conformance of CNS 14-215-H Series A cask with specifications for Industrial Packaging Type A and Type 2 IG 20003, 02 Task performance procedure training for temporary technicians Revision 3 IG 30075, 01 Lesson plan, Radioactive material receipt and transfer Revision 5 IG 60045, 01 Lesson plan, General awareness and safety training Revision 1 IG 60045, 02 Lesson plan, Warehouse personnel function specific Revision 1 IG 60045, 03 Lesson plan, Radwaste function specific Revision 1 NG-00-1500 Memorandum, Radwaste operator 49 CFR 172.704 August 28, 2000 NG-01-0258 Memorandum, DAEC Subpart H training February 26, 2001 NG-01-0491 Memorandum, Authorization to prepare and verify radioactive material/waste shipping paperwork April 12, 2001 NG-01-1451 Function specific tasks for health physics technicians December 21, 2001 RW-S-28 Waste processor shipment pre-release checklist Revision 3 STD-R-02-050 Test and evaluation document US DOT Specification 7A, type A packaging for ATG casks Radioactive Material Shipment, RSR #00-17 Miscellaneous waste October 24, 2000 Radioactive Material Shipment, RSR #00-21 Condensate Resin December 13, 2000 Radioactive Material Shipment, RSR #01-19 Low Pressure MSR bundle April 30, 2001 Radioactive Material Shipment, RSR #01-35 Refueling equipment May 24, 2001
Radioactive Material Shipment, RSR #01-55 Dry Active Waste October 2, 2001 Radioactive Material Shipment, RSR #01-60 Fuel scrapings/CAV sample November 2, 2001 Radioactive Material Shipment, RSR #01-64 Condensate Resin December 10, 2001 02-438 Survey of Limited quantity shipment package, Composite air filter samples February 28, 2002 Course 70001LAUNDRY, Radwaste shipper function specific, Laundry shipment exam Revision 0 Listing of all Non-Excepted package shipments since August, 2000 Memorandum, Course 70001RADMAN, Subpart H training March 29, 2001 Print-out of currently qualified 49CFR172 Subpart H, DAEC personnel February 22, 2002 40A1 Performance Indicator Verification Radiation Protection PI Action Request Items AR 25447 Revise OI 261 procedure (RWCU) to limit flow with both demineralizer beds in operation May 4, 2001 AR 25918 Valve line-up in OI 261 (RWCU) is incorrect May 19, 2001 AR 29650 Dose conversion factors for calculation of dose equivalent I-131 revised January 25, 2002
Procedures ACP 1402.4 NRC Performance Indicator collection and reporting.
Attachment 1, PI data calculation, review and approval. First, Second, Third and Fourth Quarters, 2001 data.
Revision 0 PCP 1.2 DAEC Chemistry quality assurance program Revision 16 PCP 1.9 Water chemistry guidelines Revision 21 PCP 2.
Plant chemistry sampling program guidelines Revision 8 PCP 2.13 Reactor water sampling Revision 11 PCP 2.2 Collection of liquid grab samples from sample stations and local sample points Revision 1 PCP 6.11 Gross Gamma activity Revision 1 PCP 6.13 Reactor water Iodine Revision 2 PCP 7.3 Nuclear data spectroscopy system operation Revision 21 STP 3.4.6-01 DAEC Reactor coolant Iodine activity, results of sampling, February 26, 2001 Revision 1 Miscellaneous Data Plant chemistry procedures, 3200 Manual Index February 8, 2002 Emergency Preparedness PI 1999 DAEC Siren Monthly Operability Report 2000 DAEC Siren Monthly Operability Report 2001 DAEC Siren Monthly Operability Report ACP 1402.4 NRC Performance Indicator Collection and Reporting
- PI Data Calculation, Review and Approval 4th Quarter 1999 Through 3rd Quarter 2001 EPDM 1010 EP Department Performance Indicators (PIs)
Revision 0 Unavailability PI Memo DAEC 4th Qtr. 2001 PI Summary January 25, 2002 Memo DAEC 3rd Qtr. 2001 PI Summary October 19, 2001 AR 26830 Review Events for 2/99 (FIC3509 OOT), 10/99 (FIC2509 OOT), 7/99 (V24-0058 Repair) and 4/01 (MO2401 Failure) to Determine if MPFFs
[Maintenance Preventable Functional Failures]
August 3, 2001
AR 27449 RCIC Steam Supply Isolation Valve MO2401 (RCIC Steam Supply Outboard Isolation) Failed to Meet ASME for Opening August 30, 2001 Operator Logs July 1 through December 31, 2001 AR 27423 RCIC Flow Controller Indicates 15 GPM in Standby Following Maintenance August 30, 2001