IR 05000333/2006003
| ML062010540 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/20/2006 |
| From: | Cobey E Reactor Projects Branch 2 |
| To: | Peter Dietrich Entergy Nuclear Northeast |
| References | |
| IR-06-003 | |
| Download: ML062010540 (25) | |
Text
uly 20, 2006
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000333/2006003
Dear Mr. Dietrich:
On June 30, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant. The enclosed integrated inspection report documents the inspection results, which were discussed on July 6, 2006, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one finding of very low safety significance (Severity Level IV). The finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the James A. FitzPatrick Nuclear Power Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Eugene W. Cobey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No.: 50-333 License No.: DPR-59 Enclosure: Inspection Report 05000333/2006003 w/Attachment: Supplemental Information
SUMMARY OF FINDINGS
IR 05000333/2006-003; 04/01/2006 - 06/30/2006; James A. FitzPatrick Nuclear Power Plant;
Licensed Operator Requalification Program.
The report covered a 3-month period of inspection by resident inspectors and announced inspections by four regional specialist inspectors. One Severity Level IV (SLIV) non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- SLIV. The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.74(c), in that, on multiple occasions, Entergy had not reported that licensed operators were taking prescription medications to control potentially disqualifying medical conditions. Once brought to the licensees attention, this issue was promptly added to their corrective action program. The corrective actions included an extent of condition review by Entergys medical department and subsequent submission of the required reports to the NRC.
The inspectors determined that Entergys failure to report potentially disqualifying medical conditions in accordance with 10 CFR 50.74(c) is a performance deficiency. The inspectors also determined that this issue was within Entergys ability to foresee and prevent. In addition, the inspectors determined that traditional enforcement applies because failure to report to the NRC potentially disqualifying medical conditions of operators impacts the NRCs regulatory function. The inspectors determined that the finding was Severity Level IV using the NRCs Enforcement Policy and Inspection Manual Chapter 0609, Appendix I,
Licensed Operator Requalification Significance Determination Process (SDP).
Specifically, it involved the failure to report the use of medication to control potentially disqualifying medical conditions in greater than 20 percent of the records reviewed. (Section 1R11)
Licensee-Identified Violations
None.
iii
REPORT DETAILS
Summary of Plant Status
The James A. FitzPatrick plant began the inspection period at full rated thermal power and operated at or near full power for the entire report period, except for a planned power reduction to 55 percent to replace the B reactor feed water pump seal on April 19, 2006 and an unplanned power reduction to 75 percent to repair condenser tube leaks on May 30,
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
b. Inspection Scope
The inspectors completed one adverse weather protection sample. The inspectors reviewed and verified completion of the operations department warm weather preparation checklist contained in procedure AP-12.04, Seasonal Weather Preparations. The inspectors reviewed the operating status of the emergency and normal service water systems, reviewed the procedural limits and actions associated with elevated lake temperature, and walked down accessible portions of the systems to assess their readiness. Documents reviewed for this inspection are listed in the
.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment (71111.04 - 3 samples,
==71111.04S - 1 sample)
a. Inspection Scope
==
Partial System Walkdown. The inspectors performed three partial system walkdowns, each constituting inspection program samples, to verify equipment alignment and to identify any discrepancies that could potentially increase risk, cause initiating events, or impact the system operability. The inspectors compared system lineups to system operating procedures, system drawings, and the applicable chapters in the Updated Final Safety Analysis Report. The inspectors also verified the operability of critical system components by observing component material condition during the system walkdown and reviewing the maintenance history for each component. The documents reviewed during this inspection are listed in the Attachment.
The inspectors performed partial walkdowns of the following systems:
- Train A residual heat removal service water (RHRSW) system on June 12, while maintenance was conducted on train B RHRSW;
- A and C emergency diesel generator (EDG) subsystems on June 13, while subsystems B and D were out of service for planned maintenance; and
- High pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC)systems on June 21 and 22, while performing an automatic depressurization system (ADS) logic test and troubleshooting an inoperable safety relief valve.
Complete System Walkdown. The inspectors performed a complete walkdown of the RCIC system to identify any discrepancies between the existing equipment lineup and the required lineup. This walkdown constituted one inspection sample. During the walkdown, system drawings and operating procedures were used to verify proper equipment alignment and operational status. The inspectors reviewed the open maintenance work requests associated with the system for any deficiencies that could affect the ability of the system to perform its function. Documentation associated with unresolved design issues such as temporary modifications, operator work-arounds, and items tracked by plant engineering were also reviewed to assess their collective impact on system operation. In addition, the inspectors reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved. The documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
Quarterly. The inspectors toured eight areas important to reactor safety to evaluate conditions related to Entergys control of transient combustibles and ignition sources; the material condition, operational status, and operational lineup of fire protection systems, equipment and features; and the fire barriers used to prevent fire damage or fire propagation. The inspectors used procedure ENN-DC-161, Transient Combustible Program, in performing the inspection. The documents reviewed during this inspection are listed in the Attachment. The areas inspected constituting eight inspection program samples included:
- Relay room;
- Cable spreading room;
- East crescent area;
- West crescent area;
- Main, reserve and station transformers;
- Screenwell building;
- EDG switchgear areas; and
- Outside yard and independent spent fuel storage cask areas.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review
a. Inspection Scope
On May 10, 2006, the inspectors observed licensed operator simulator training to assess operator performance during several scenarios. The inspectors evaluated the performance of risk significant operator actions, including the use of emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operation and manipulation, and the oversight and direction provided by the shift manager. The inspectors also reviewed simulator fidelity to evaluate the degree of similarity to the actual control room. This observation of operator simulator training constituted one inspection program sample. The documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Biennial Review
a. Inspection Scope
The effectiveness of the licensed operator requalification training program was evaluated through reviews of the following documents related to the facility operating history for the past two years:
C NRC inspection reports and plant issue matrix; C Licensee event reports; and C Operator and training related condition reports.
The quality and content of the requalification examinations were evaluated during reviews of two reactor operator and two senior reactor operator written tests from the last biennial comprehensive examination, observations of operating examinations administered during the two weeks of this inspection, and a survey of the facilitys requalification scenarios and job performance measures (JPM) banks.
This review assessed the coverage of the examinations as specified in Title 10 of the Code of Federal Regulations (CFR), Parts 55.41, 55.43, and 55.59, and the inclusion of probabilistic risk assessment insights. The discrimination level and construction of the examinations were also evaluated against the criteria set forth in NUREG -1021, Operator Licensing Examination Standards for Power Reactors.
Licensed operator training on important tasks identified in the Individual Plant Examination was verified by reviewing a list of the top 20 risk significant cutsets involving all operator actions and the top 10 cutsets involving local operator actions and verifying a link to a training item for these tasks.
Observations of examination administration and grading practices for two crews were conducted, including evaluator review of final grading reports.
Entergys updating of the requalification program was assessed by review of plant and procedure modifications and industry events, and verification of appropriate updating of both specific system lesson plans and generic plant and industry events lessons.
Remediation practices were assessed by review of instances in which operators or crews had failed either a written examination or simulator evaluation during the current requalification program. Two examples of a failed cold evaluation at the start of a training week and subsequent remediation were reviewed. One example of a failed biennial written exam and reexamination was reviewed.
Utilization of feedback to update and modify the requalification program was evaluated by verification of training on plant modifications and plant and industry events.
Operators were interviewed to discuss the effectiveness of the feedback process.
Compliance with license conditions was verified through review of attendance records and medical reviews for the two crews observed during this inspection. Watchstanding proficiency and reactivation documentation was reviewed for all licensed operators.
For the site specific simulator, the inspectors observed simulator performance during the conduct of the examinations and reviewed simulator performance tests and simulator action requests to verify compliance with the requirements of 10 CFR 55.46. The following tests and data were reviewed:
C Priority scheme for all currently open and closed (i.e., in the past two year period) simulator action requests; C Steady state test data for 75 percent and 100 percent tests; and C Transient tests for manual scram, simultaneous trip of all reactor recirculation pumps, and design basis loss of coolant accident.
The inspectors reviewed overall annual operating test results upon completion of all examination weeks. The inspectors verified that greater than 80 percent of operators had passed their examination (pass rate was 98 percent).
b. Findings
.1 Operator Medical Records
Introduction:
The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 50.74(c), in that, on multiple occasions Entergy had not reported that licensed operators were taking prescription medications to control potentially disqualifying medical conditions.
Description:
Licensed operators at FitzPatrick are required to satisfy physical requirements as described in 10 CFR 55.33, NRC Regulatory Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants, and ANS/ANSI 3.4 -1996, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. Potentially disqualifying medical conditions must be reported to the NRC within 30 days as required by 10 CFR 50.74, even if those conditions are adequately controlled by medication. For three of twelve operators evaluated, medical records indicated that they had been taking prescription medication for up to eight years to control potentially disqualifying medical conditions, and no reports concerning the conditions had been provided to the NRC.
Analysis:
The inspectors determined that Entergys failure to report potentially disqualifying medical conditions in accordance with 10 CFR 50.74(c) is a performance deficiency. The inspectors also determined that this issue was within Entergys ability to foresee and prevent. In addition, the inspectors determined that traditional enforcement applies because failure to report to the NRC potentially disqualifying medical conditions of operators impacts the NRCs regulatory function. The inspectors determined that the finding was ``Severity Level IV using the NRCs Enforcement Policy and Inspection Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP). Specifically, it involved the failure to report the use of medication to control potentially disqualifying medical conditions in greater than 20 percent of the records reviewed.
Enforcement:
10 CFR 50.74(c) requires, in part, that the NRC be notified within 30 days of the identification of a permanent disability or illness as described in 10 CFR 55.25.
Contrary to the above, in 25 percent of records reviewed from 1998 to 2006, licensed operators were taking prescription medication to control potentially disqualifying medical conditions and no report had been made to the NRC. The corrective action will include an extent of condition review by Entergys medical department and providing the required reports to the NRC. Because this failure to comply with medical reporting requirements is a Severity Level IV violation and it has been entered into Entergys corrective action program as condition report (CR) 2006-02026, this violation is being treated as an NCV consistent with section VI.A.1 of the NRC Enforcement Policy:
NCV 05000333/2006003-01, Failure to Provide Required Medical Report.
.2 Simulator Transient Testing
Introduction:
10 CFR 55.46(d)(1) requires, in part, that continued assurance of simulator fidelity be maintained by conducting performance testing throughout the life of the simulation facility. The performance testing requirements committed to by Entergy are stated in ANS/ANSI 3.5 -1985, Nuclear Power Plant Simulators for Use in Operator Training, and endorsed by the NRC via Regulatory Guide 1.149, Nuclear Power Plant Simulation Facilities for use in Operator Training and License Examinations, Revision 1.
ANS/ANSI 3.5 -1985 stipulates that annual transient testing results be compared to either actual plant data or best estimate data.
Description:
The inspector noted that the FitzPatrick training staff establishes the acceptability of the simulator transient test data by comparing current year transient data to prior year test results rather than actual plant data or best estimate data as specified in ANS/ANSI 3.5 -1985. Because Entergys methodology deviates from ANSI guidance for simulator testing, the inspectors determined that the potential exists for deviations to be introduced between the actual plant response and the plant reference simulator response for certain transients. These deviations may lead to negative training, which in turn could have an adverse effect on operator actions during plant operations.
This issue is potentially more than minor because it affected the human performance attribute of the Mitigating Systems Cornerstone, in that, simulator deviations can result in human error during event response. This issue is unresolved pending Entergys further review of simulator transient test results to determine if any such simulator performance deviations are present. This issue has been entered in the corrective action program as CR 2006-02057. URI 05000333/2006003-02, Simulator Transient Testing.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures, systems, or components (SSCs) to assess the effectiveness of the maintenance program. Reviews focused on:
- Proper Maintenance Rule (MR) scoping in accordance with 10 CFR 50.65;
- Characterization of reliability issues;
- Changing system and component unavailability;
- 10 CFR 50.65 (a)(1) and (a)(2) classifications;
- Identifying and addressing common cause failures;
- Trending system flow and temperature values;
- Appropriateness of performance criteria for SSCs classified (a)(2); and
- Adequacy of goals and corrective actions for SSCs classified (a)(1).
The inspectors reviewed system health reports, maintenance backlogs, and Maintenance Rule basis documents. The documents reviewed during this inspection are listed in the Attachment. The following three maintenance rule samples were reviewed:
- Service water and emergency service water systems;
- Air treatment systems; and
- Exhaust stack high range radiation monitors.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed risk assessments associated with five different work weeks during the inspection period, each constituting one inspection program sample. The inspectors verified that risk assessments were performed in accordance with AP-10.10, On-line Risk Assessment; that risk of scheduled work was managed through the use of compensatory actions and schedule adherence; and that applicable contingency plans were properly identified in the integrated work schedule. The following work weeks were reviewed:
- Week of April 3, 2006 that included a planned outage of the A residual heat removal (RHR) and RHRSW trains;
- Week of April 24, 2006 that included preventive maintenance on reserve station transformer T-3 and 115 kilovolt (kV) off-site power line #3;
- Week of May 15, 2006 that included declaring 115 kV off-site power line #4 inoperable for preventive maintenance at Nine Mile Point Nuclear Station;
- Week of June 12, 2006 that included replacement of a reactor protection system voltage regulator.
b. Findings
No findings of significance were identified.
1R14 Operator Performance During Non-Routine Evolutions and Events
b. Inspection Scope
On May 30, 2006, operators reduced reactor power to 75 percent due to high condenser hotwell and reactor coolant conductivity caused by leakage into the B main condenser waterbox. The inspectors observed operator actions in the control room and reviewed operator logs, plant computer data, and strip charts to determine what occurred and how the operators responded, and to determine if the response was in accordance with plant procedures. The documents reviewed during this inspection are listed in the
. This constituted one program sample.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed operability determinations to assess the acceptability of the evaluations; when applicable, the use and control of compensatory measures; and the compliance with Technical Specifications (TS). The inspectors review included a verification that the operability determinations were made as specified by ENN-OP-104, Operability Determinations. The technical adequacy of the determinations was reviewed and compared to the TS, UFSAR, and associated design basis documents.
The following six evaluations were reviewed, and each constituted inspection program samples:
- CR 2006-01495 concerning B EDG turbocharger post engine run lube oil low pressure;
- CR 2006-01846 concerning B and D EDG load anomalies during surveillance test;
- CR 2006-01570 concerning operability of the relay room ventilation system upon failure of air handling unit 70AHU-12B;
- CR 2006-02127 concerning a potential 10 CFR Part 21 notification regarding the environmental qualification of pressure transmitters;
- CR 2005-01294 concerning technical justifications for deferral of jet pump beam inspections; and
- Operations shift standing orders concerning off-gas system boundary leaks, monitoring and action plans for significant leaks, main turbine electro-hydraulic control electrical malfunction light, unidentified drywell leakage, and EPIC computer room air conditioner leakage.
b. Findings
No findings of significance were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
The inspectors reviewed post maintenance test procedures and associated testing activities for selected risk significant mitigating systems to assess whether the effect of maintenance on plant systems was adequately addressed by control room and engineering personnel. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness and were consistent with design basis documents; that test instrumentation had current calibrations and the appropriate range and accuracy for the application; and that tests were performed as written with applicable prerequisites satisfied. Upon completion, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function. The documents reviewed during this inspection are listed in the Attachment. The following five post maintenance test activities were reviewed, and constitute inspection program samples.
- Work Request (WR) [[::JAF-04-26547|JAF-04-26547]], which involved periodic maintenance on the B reactor protection system motor generator set including replacement of the voltage regulator. The retest consisted of functional and operational checks in accordance with the WR instructions.
- WRs [[::JAF-04-18606|JAF-04-18606]] and [[::JAF-06-15843|JAF-06-15843]], which involved periodic and corrective maintenance on the A train drywell continuous atmospheric monitor. The retest consisted of operational checks per RP-RESP-03.01, Drywell Continuous Atmospheric Monitoring System.
- WRs [[::JAF-06-18999|JAF-06-18999]] and JF-020070600, which involved replacement of the governor-actuator and motor-operated potentiometer on the D EDG. The retest was performed using TST-128D, EDG D Governor Control Operability Test, and ST-9BB, EDG B and D Full Load Test and ESW Pump Operability Test.
- WR [[::JAF-06-21088|JAF-06-21088]], which replaced the remote shutdown panel 25ASP-5 transfer switch for safety relief valve 02RV-71D. The retest was performed in accordance with the WR which followed applicable portions of ST-22C, ADS Logic System Functional Test.
- WR [[::JAF-04-30126|JAF-04-30126]], which inspected and repaired RHRSW keep-full check valve 10RHR-431A. The retest consisted of an operational leakage check and verification of forward flow in accordance with the WR.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors witnessed performance of surveillance test procedures and reviewed test data of selected risk-significant SSCs to assess whether the SSCs satisfied Technical Specifications, Updated Final Safety Analysis Report, Technical Requirements Manual, and Entergy procedure requirements. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness and were consistent with design basis documents; that test instrumentation had current calibrations and the appropriate range and accuracy for the application; and that tests were performed as written with applicable prerequisites satisfied. Upon the completion of the surveillance test, the inspectors verified that equipment was returned to the status specified to perform its safety function. Six tests were reviewed, and constitute inspection program samples:
- ST-8Q, Testing of the Emergency Service Water System (IST);
- RP-RESP-03.02, SGTS, CREVAS, and TSCVAS Testing; and
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness [EP]
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed simulator activities associated with the licensed operator requalification training graded scenario on May 10, 2006. The inspectors verified that emergency classification declarations and notification activities were properly completed as required by IAP-2, Classification of Emergency Conditions. This observation constituted one inspection sample.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program (CAP)
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into Entergys corrective action program. The review was accomplished by accessing Entergys computerized database for Condition Reports (CRs) and attending CR screening meetings.
In accordance with the baseline inspection modules the inspectors selected corrective action program items across the initiating events, mitigating systems, barrier integrity, and public radiation safety cornerstones for additional follow-up and review. The inspectors assessed Entergys threshold for problem identification, the adequacy of the cause analyses, extent of condition review, and operability determinations, and the timeliness of the specified corrective actions. The CRs reviewed are noted in the attachment.
.2 Semi-Annual Review to Identify Trends
As required by Inspection Procedure 71152, Identification and Resolution of Problems, the inspectors performed a review of the Entergys Corrective Action Program (CAP) and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.1. The review also included issues documented outside the normal CAP in system health reports, corrective maintenance work requestss, component status reports, site monthly meeting reports and maintenance rule assessments. The inspectors review nominally considered the six-month period of January through June 2006, although some examples expanded beyond those dates when the scope of the trend warranted. The inspectors compared and contrasted their results with the results contained in the licensees latest integrated quarterly assessment report. Corrective actions associated with a sample of the issues identified in the licensees trend report were reviewed for adequacy. The inspectors also evaluated the trend report specified in ENN-LI-102, Corrective Action Process, and 10 CFR 50, Appendix B. The documents reviewed during this inspection are listed in the
.
b. Assessment and Observations Equipment, human performance and program issues were identified at an appropriate threshold and were entered into the problem identification and resolution program. No findings of significance were identified.
.3 Annual Sample: Offsite Power Line Bus Connector Failure Review
a. Inspection Scope
The inspectors reviewed Entergys corrective actions in response to the #4 offsite power line bus connector failure identified in CR 2005-05180, Input Bushing to 71BRK-10012 Was Found to be Disconnected. The inspectors also reviewed additional corrective actions documented in a related condition report, CR 2005-05289, 115 kV Line #4 Was Unable to Perform Its Function During the Period From 11/29/05 to 12/21/2005.
The inspectors reviewed the probable cause evaluations to verify that corrective actions were consistent with the identified causes, adequate to prevent recurrence, and reasonably addressed contributing factors. The inspectors reviewed maintenance and operating procedure changes to verify that they had been promptly implemented.
b. Assessment and Observations The corrective action program was effective in resolving the offsite power line bus connector failure. Non-cited violation 05000333/2005006-03 was issued previously to document Entergys noncompliance with Technical Specifications 3.8.1 regarding operation with one offsite power circuit inoperable. No findings of significance were identified.
.4 Annual Sample: Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of operator workarounds on the reliability, availability, and potential for mis-operation of a system and on the effect of the operator workaround on the operators ability to implement abnormal or emergency operating procedures. The inspectors reviewed the results of FitzPatrick assessment ST-99H, Operations Cumulative Impact Assessment, and the resolution of items identified in the assessment. The inspectors reviewed FitzPatricks program to identify operator workarounds at an appropriate threshold and to enter them into the corrective action program. In addition, operations department records including operations standing orders for operational decision making issues and the operability evaluation records were reviewed.
b. Assessment and Observations The corrective action program was effectively used to identify and resolve operator workarounds. The resolution of operator workarounds has been effectively prioritized.
No findings of significance were identified.
4OA3 Event Follow-up
.1 (Closed) LER 05000333/2006001-00, Inoperable Reactor Building-To-Suppression
Chamber Vacuum Breaker in Excess of Technical Specifications Allowed Out of Service Time.
Between February 23, 2006 and March 6, 2006, reactor-to-suppression chamber vacuum breaker 27AOV-101A was inoperable due to being not fully closed. The condition exceeded the three-day allowed outage time specified by Technical Specification 3.6.1.6 for an open reactor-to-suppression chamber vacuum breaker. The violation occurred because the valve erroneously indicated closed in the control room. Entergy identified that the valve was not fully closed while investigating the cause of a rising oxygen concentration in the suppression chamber. The enforcement aspects of this violation are documented in section 4OA7 of inspection report 05000333/2006002. Entergy entered the event into its corrective action program as CR-2006-00979. This LER is closed.
4OA5 Other Activities
.1 Implementation of Temporary Instruction (TI) 2515/165 - Operational Readiness of
Offsite Power and Impact on Plant Risk
a. Inspection Scope
The objective of TI 2515/165, Operational Readiness of Offsite Power and Impact on Plant Risk, was to gather information to support the assessment of nuclear power plant operational readiness of offsite power systems and impact on plant risk. The inspector evaluated Entergys procedures against the specific offsite power, risk assessment, and system grid reliability requirements of TI 2515/165. The inspector also discussed the attributes with Entergy personnel.
The information gathered while completing this TI was forwarded to the Office of Nuclear Reactor Regulation for further review and evaluation on April 3, 2006.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On July 6, 2006, the inspectors presented the inspection results to Mr. Peter T. Dietrich and other members of his staff, who acknowledged the finding. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Entergy Personnel
- P. Dietrich, Vice President, Operations
- D. Wallace, Director, Nuclear Safety Assurance
- K. Mulligan, General Manager, Plant Operations
- N. Avrakotos, Manager, Emergency Preparedness
- J. Costedio, Manager, Regulatory Compliance
- M. Durr, Manager, System Engineering
- J. Gerety, Manager, Design Engineering
- D. Johnson, Manager, Operations
- J. LaPlante, Manager, Security
- A. McKeen, Manager, Radiation Protection
- J. Pechacek, Manager, Programs and Components Engineering
- M. Jacobs, Manager, Training
- W. Rheaume, Manager, CA&A
- B. Sholler, Manager, Plant Maintenance
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000333/2006003-02 URI Simulator Transient Testing
Opened and Closed
- 05000333/2006001-00 LER Inoperable Reactor Building-To-Suppression Chamber Vacuum Breaker in Excess of Technical Specifications Allowed Out of Service Time
- 05000333/2006003-01 NCV Failure to Provide Required Medical Report