IR 05000331/2014002
| ML14121A147 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 04/30/2014 |
| From: | Christine Lipa NRC/RGN-III/DRP/B1 |
| To: | Richard Anderson NextEra Energy Duane Arnold |
| References | |
| IR-14-002 | |
| Download: ML14121A147 (31) | |
Text
April 30, 2014
SUBJECT:
DUANE ARNOLD ENERGY CENTER - NRC INTEGRATED INSPECTION REPORT 05000331/2014002
Dear Mr. Anderson:
On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Duane Arnold Energy Center. The enclosed report documents the results of this inspection, which were discussed on April 17, 2014, with you and other members of your staff.
Based on the results of this inspection, no findings of significance were identified.
As we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Duane Arnold Energy Center.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Christine Lipa, Chief Branch 1 Division of Reactor Projects
Docket No. 50-331 License No. DPR-49
Enclosure:
Inspection Report 05000331/2014002 w/Attachment: Supplemental Information
REGION III==
Docket No:
50-331 License No:
DPR-49 Report No:
05000331/2014002 Licensee:
NextEra Energy Duane Arnold, LLC Facility:
Duane Arnold Energy Center Location:
Palo, IA Dates:
January 1 through March 31, 2014 Inspectors:
L. Haeg, Senior Resident Inspector
J. Steffes, Resident Inspector
R. Elliott, Resident Inspector, Acting
R. Baker, Operations Engineer
B. Cushman, Resident Inspector, Quad Cities
V. Myers, Health Physicist
Approved by:
Christine Lipa, Chief Branch 1 Division of Reactor Projects
SUMMARY OF FINDINGS
Inspection Report (IR) 05000331/2014002, 01/01/2014 - 03/31/2014; Duane Arnold Energy
Center.
This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using IMC 0609, Significance Determination Process dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.
NRC-Identified
and Self-Revealed Findings No findings were identified during this inspection.
Licensee-Identified Violations
No findings were identified during this inspection.
REPORT DETAILS
Summary of Plant Status
Duane Arnold Energy Center (DAEC) operated at full power for the entire inspection period except for brief down-power maneuvers to accomplish rod pattern adjustments or to conduct planned surveillance testing activities.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Condition - Extreme Cold Conditions/Heavy
Snowfall Conditions
a. Inspection Scope
Since extreme cold conditions were forecast in the vicinity of the facility for February 24, 2014, the inspectors reviewed the licensees overall preparations/protection for the expected weather conditions. On February 25, 2014, the inspectors walked down the pump house portions of the Emergency Service Water (ESW) and Residual Heat Removal Service Water (RHRSW) systems, and the supporting ESW/RHRSW room coolers and ventilation damper control systems, as well as validating both Standby Diesel Generator (SBDG) standby readiness checklist conditions because their safety-related functions could be affected or required as a result of the extreme cold conditions forecast for the facility. The inspectors observed insulation, heat trace circuits, space heater operation, and weatherized enclosures to ensure operability of affected systems. The inspectors reviewed licensee procedures and discussed potential compensatory measures with control room personnel. The inspectors focused on plant managements actions for implementing the stations procedures for ensuring adequate personnel for safe plant operation and emergency response would be available.
Additionally, on February 28, 2014, a winter weather advisory was issued for expected heavy snow fall in the vicinity of the plant. The inspectors observed the licensees preparations and planning for the significant winter weather potential. The inspectors reviewed licensee procedures and discussed potential compensatory measures with control room personnel. The inspectors focused on plant managements actions for implementing the stations procedures for ensuring adequate personnel for safe plant operation and emergency response would be available. The inspectors conducted a site walkdown including walkdowns of various plant structures and systems to check for maintenance or other apparent deficiencies that could affect system operations during the predicted significant weather. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report.
These inspections constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- High Pressure Coolant Injection (HPCI) with Reactor Core Isolation Cooling (RCIC) system removed from service;
- A SBDG with the B SBDG out-of-service (OOS) for performance of the 24-month inspection maintenance;
- B Core Spray system and both trains of the RHRSW systems with the B loop of Low Pressure Coolant Injection (LPCI) OOS for 24-month surveillance testing; and
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.
The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies.
The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
These inspections constituted four quarterly partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
During the week of February 2, 2014, the inspectors performed a complete system alignment inspection of A Low Pressure Emergency Core Cooling subsystems to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on the availability, accessibility, and condition of firefighting equipment in the following risk-significant plant areas:
- Pre-Fire Plan (PFP)-RB-716; Pre-Fire Plan Reactor Building El. 716;
- PFP-RB-786; Pre-Fire Plan Reactor Building El. 786;
- Area Fire Plan (AFP)-09; RBCCW Heat Exchanger Area, Equipment Hatch Area, and Jungle Room Elevation 812-0;
- AFP-12; Decay Tank and Condensate Phase Separator Room; and
- AFP-79; Spent Fuel Storage Facility.
The inspectors reviewed these areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or non-functional fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected these fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.
These inspections constituted five routine resident inspector tour samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
.2 Annual Fire Protection Drill Observation
a. Inspection Scope
On March 17, 2014, the inspectors observed a fire brigade activation for a simulated fire in the pump house. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:
- proper wearing of turnout gear and self-contained breathing apparatus;
- proper use and layout of fire hoses;
- employment of appropriate firefighting techniques;
- sufficient firefighting equipment brought to the scene;
- effectiveness of fire brigade leader communications, command, and control;
- search for victims and propagation of the fire into other plant areas;
- smoke removal operations;
- utilization of pre-planned strategies;
- adherence to the pre-planned drill scenario; and
- drill objectives.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one annual fire protection drill observation sample as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding
.1 Internal Flooding
a. Inspection Scope
The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items identified in the CAP to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant areas to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:
- reactor building, with a focus on radioactive waste sump system management.
Documents reviewed during this inspection are listed in the Attachment to this report.
This inspection constituted one internal flooding sample as defined in IP 71111.06-05.
b. Findings
No findings were identified.
1R07 Annual Heat Sink Performance
.1 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the licensees testing of the A Residual Heat Removal (RHR)heat exchanger to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed are listed in the Attachment to this document.
This inspection constituted one annual heat sink performance sample as defined in IP 71111.07-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On February 10, 2014, the inspectors observed crews of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas of the crew:
- licensed operator performance;
- clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one resident inspector quarterly review of licensed operator requalification sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
a. Inspection Scope
On January 31, 2014, through February 1, 2014, the inspectors observed operators in the control room during a planned downpower for a scheduled control rod sequence exchange pattern adjustment, maintenance to replace the CV-1058, Moisture Separator Reheater Scavenging Steam Supply, solenoid, and required quarterly Main Turbine and Bypass Valves surveillance testing. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas of the crew:
- licensed operator performance;
- clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board (or equipment) manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions.
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one resident inspector quarterly observation of heightened activity or risk sample as defined in IP 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- Reactor Water Cleanup (RWCU) system; and
- SBDG system.
The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two routine quarterly evaluation samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- Work Week 1402 Risk: Testing of critical offsite power cables, Abnormal Operating Procedure (AOP) 903, Severe Weather, entry due to high winds and emergent work associated with primary containment isolation valve (PCIV) indication failure, steam seal valve failure and 4 Kilovolt (kV) emergency transfer under-voltage relay failure;
- Work Week 1405 Risk: B SBDG maintenance;
- Work Week 1406 Risk: 24-month B LPCI Subsystem Simulated Automatic Actuation surveillance test following significant RHR system motor operated valve maintenance, and B 4 kV Emergency Bus Degraded Voltage functional test; and
- Work Week 1410 Risk: RHR maintenance.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted four maintenance risk assessments and emergent work control samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- B and D River Water Supply (RWS) pumps differential pressure values remain in the American Society of Mechanical Engineers (ASME) alert range;
- Standby Liquid Control (SBLC) System Leak discovered during pump operability testing;
- J breaker low insulation resistance measurement; and
- B reactor recirculation pump mini-purge PCIV.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
These inspections constituted four operability evaluation samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modification:
- B reactor recirculation pump mini-purge PCIV monitoring equipment temporary modification.
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one plant modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- Calibration of Reactor Core Isolation Cooling Turbine Tachometer Circuit;
- A Standby Filter Unit testing following planned maintenance to replace charcoal and HEPA filters;
- B SBDG Overspeed trip testing during performance of the planned 24 month inspection maintenance and heat exchanger tube bundle replacement;
- STP 3.8.1-06B; B SBDG Operability Test (Fast Start) following planned maintenance; and
- B ESW system operability testing following planned maintenance to install an engineering change package modification on the B ESW pump motor control circuit.
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted five post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- Surveillance Frequency Control Program review resulting from 125 VDC and 250 VDC missed battery surveillances (Routine);
- STP 3.1.7-01; SBLC Pump Operability Test; Revision 36 (In-service Test);
- Quarterly Main Turbine Surveillance Testing which included:
- (1) STP NS930002; Main Turbine Stop and Combined Intermediate Valves Test; Revision 5;
[Recirculation Pump Trip] Logic and RPS [Reactor Protection System] Instrument Functional Test; Revision 15;
- (4) STP 3.7.7-01; Bypass Valves Test; Revision 17 (Routine); and
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the UFSAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted four routine surveillance testing samples, and one in-service testing sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill involving a hostile action based scenario, on March 5, 2014, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Control Room Simulator, Emergency Offsite Facility, and the Alternative Technical Support Center, to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.
The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.
This inspection constituted one emergency preparedness drill observation sample as defined in IP 71114.06-05.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation (71124.08) This inspection constituted one complete sample as defined in IP 71124.08-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the solid radioactive waste system description in the UFSAR, the Process Control Program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.
The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensees performance and inform the smart sampling inspection planning.
b. Findings
No findings were identified.
.2 Radioactive Material Storage (02.02)
a. Inspection Scope
The inspectors selected areas where containers of radioactive waste are stored and evaluated, whether the containers were labeled in accordance with 10 CFR 20.1904, Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to Labeling Requirements, as appropriate.
The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20, Standards for Protection against Radiation. For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, Security of Stored Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.
The inspectors evaluated whether the licensee established a process for monitoring the impact of long term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.
The inspectors selected containers of stored radioactive material, and assessed for signs of swelling, leakage, and deformation.
b. Findings
No findings were identified.
.3 Radioactive Waste System Walkdown (02.03)
a. Inspection Scope
The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in the UFSAR, Offsite Dose Calculation Manual, and Process Control Program.
The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment which is not in service or abandoned in place would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure.
The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, Changes, Tests, and Experiments.
The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes from what is described in the UFSAR were reviewed and documented in accordance with 10 CFR 50.59 as appropriate and to assess the impact on radiation doses to members of the public.
The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the Process Control Program, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, Waste Classification.
For those systems that provide tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing.
The inspectors assessed whether the licensees Process Control Program correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid).
b. Findings
No findings were identified.
.4 Waste Characterization and Classification (02.04)
a. Inspection Scope
The inspectors selected the following radioactive waste streams for review:
- Condensate Resin;
- Reactor Water Clean-up Resin; and
- Dry Active Waste.
For the waste streams listed above, the inspectors assessed whether the licensees radiochemical sample analysis results (i.e., 10 CFR Part 61" analysis) were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated whether the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound based on current 10 CFR Part 61 analysis for the selected radioactive waste streams.
The inspectors evaluated whether changes to plant operational parameters were taken into account to:
- (1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and
- (2) assure that waste shipments continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above.
The inspectors evaluated whether the licensee established and maintained an adequate Quality Assurance Program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste Characteristics.
b. Findings
No findings were identified.
.5 Shipment Preparation (02.05)
a. Inspection Scope
The inspectors reviewed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for cask loading and closure procedures were consistent with the vendors current approved procedures.
Due to limited opportunities for direct observation, the inspectors reviewed the technical instructions presented to workers during routine training. The inspectors assessed whether the licensees Training Program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.
b. Findings
No findings were identified.
.6 Shipping Records (02.06)
a. Inspection Scope
The inspectors evaluated whether the shipping documents indicated the proper shipping name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number for the following radioactive shipments:
- 12-11;
- 12-13;
- 12-66; and
- 13-26.
Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation.
b. Findings
No findings were identified.
.7 Identification and Resolution of Problems (02.07)
a. Inspection Scope
The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensees CAP. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation.
The inspectors reviewed results of selected audits performed since the last inspection of this program and evaluated the adequacy of the licensees corrective actions for issues identified during those audits.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours performance indicator (PI) for the period from the first quarter, 2013 through the fourth quarter, 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports and NRC Integrated Inspection Reports for the period of January 1, 2013 through December 31, 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.
This inspection constituted one unplanned scrams per 7000 critical hours sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Unplanned Scrams with Complications
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams with Complications for the period from the first quarter, 2013 through the fourth quarter, 2013.
To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports and NRC Integrated Inspection Reports for the period of January 1, 2013 through December 31, 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one unplanned scrams with complications sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Unplanned Transients per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours performance indicator for the period from the first quarter 2013 through the fourth quarter 2013. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, maintenance rule records, event reports and NRC Integrated Inspection Reports for the period of January 1, 2013 through December 31, 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.
This inspection constituted one unplanned transients per 7000 critical hours sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
4OA5 Other Activities
The table below provides a cross-reference from the third and fourth quarter 2013 findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January, 2014, will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.
Finding Old Cross-Cutting Aspect
New Cross-Cutting Aspect 05000331/2013004-01 H.1(a)
H.13 05000331/2013004-02 P.1(b)
P.4 05000331/2013004-03 P.1(c)
P.2 05000331/2013008-01 H.1(b)
H.14 05000331/2013008-02 H.1(b)
H.14 05000331/2013010-01 H.1(b)
H.14
4OA6 Management Meetings
.1
Exit Meeting Summary
On April 17, 2014, the inspectors presented the inspection results to Mr. R. Anderson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The inspection results for the area of radioactive solid waste processing and radioactive material handling, storage, and transportation with Mr. R. Porter, Radiation Protection Manager, on February 7, 2014.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Anderson, Site Vice President
- G. Pry, Plant General Manager
- K. Kleinheinz, Site Engineering Director
- M. Davis, Emergency Preparedness and Licensing Manager
- K. Peveler, Nuclear Oversight Manager
- R. Wheaton, Operations Director
- R. Porter, Radiation Protection Manager
- D. Olsen, Chemistry Manager
- J. Schwertfeger, Security Manager
- C. Hill, Training Manager
- B. Murrell, Licensing Engineer Analyst
- L. Swenzinski, Licensing Engineer
Nuclear Regulatory Commission
- C. Lipa, Chief, Reactor Projects Branch 1
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None.
Closed
None.
Discussed
None.