IR 05000333/2009004
| ML093060046 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/30/2009 |
| From: | Blake Welling Reactor Projects Branch 2 |
| To: | Peter Dietrich Entergy Nuclear Northeast |
| Welling B | |
| References | |
| IR-09-004 | |
| Download: ML093060046 (26) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000333/2009004
Dear Mr. Dietrich:
On September 30,2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed inspection report documents the inspection results which were discussed on October 8, 2009, 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 Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, this report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to be a violation of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) in accordance with Section VLA.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of the inspection report, with the basis for your denial, to the U. S.
Nuclear Regulatory Commission, AnN.: Document Control Desk, Washington, D.C. 20555 0001; with a copy to the Regional Administrator, Region I; Office of Enforcement; U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at FitzPatrick. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at FitzPatrick. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR Part 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 (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at httg:llwww.nrc.gov/reading-rmiadams.html(the Public Electronic Reading Room).
Sincerely, IRA!
Blake D. Welling, Acting Chief Projects Branch 2 Division of Reactor Projects Docket No.: 50-333 License No.: DPR-59
Enclosure:
Inspection Report 05000333/2009004 w/Attachment: Supplemental Information
REGION I==
Docket No.: 50-333 License No.: DPR-59 Report No.: 05000333/2009004 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, New York Dates: July 1 through September 30, 2009 Inspectors: G. Hunegs, Senior Resident Inspector S. Rutenkroger, PhD, Resident Inspector M. Balazik, Reactor Inspector J. Nicholson, Health Physicist M. Patel, Reactor Inspector P. Presby, Operations Engineer Approved by: Blake D. Welling, Acting Chief Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000333/2009004; 07/01/2009 - 09/30/2009; James A. FitzPatrick Nuclear Power Plant;
Equipment Alignment.
The report covered a three-month period of inspection by resident inspectors and announced inspections by region-based inspectors. One Green finding, which was a non-cited violation (NCV), was identified. The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspect for the finding was determined using IMC 0305, "Operating Reactor Assessment Program." 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 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion V,
"Instructions, Procedures, and Drawings," because Entergy personnel did not maintain an adequate high energy line break (HELB) barrier. Specifically, the inspectors identified that the HELB barrier doors between the turbine building (TB) and 'A' emergency diesel generator (EDG) switchgear room were open when required to be closed. The issue was entered into Entergy's corrective action program (CAP) as condition report (CR)-JAF 2009-02514. Entergy personnel restored the HELB barrier and provided training for operations, maintenance and supervisor personnel on proper work practices.
This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, during the timeframe that the HELB doors remained open, the reliability of the 'A' EDG subsystem to perform its safety function would be challenged during a HELB event. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency; did not represent a loss of system safety function; and did not screen as potentially risk-significant due to external initiating events.
The inspectors determined that this finding had a cross-cutting aspect in the area of human performance because Entergy supervision allowed the HELB barriers to be breached which was inconsistent with the work instructions. (H.4(c)) (Section 1R04)
Licensee-Identified Violations
- A violation of very low safety significance was identified by Entergy staff and has been reviewed by the inspectors. Corrective actions taken or planned by Entergy staff have been entered into Entergy's corrective action program. The violation and corrective action tracking number is listed in Section 40A7 of this report.
REPORT DETAILS
Summarv of Plant Status The James A. FitzPatrick Nuclear Power Plant (FitzPatrick) began the inspection period operating at 100 percent reactor power. With the exception of scheduled power reductions for control rod pattern adjustments, the plant continued to operate at or near full power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Eguipment Alignment
.1 Quarterly Partial System Walkdown
a. Inspection Scope
The inspectors performed four partial system walkdowns to verify the operability of redundant or diverse trains and components during periods of system train unavailability or following periods of maintenance. The inspectors referenced system procedures, the Updated Final Safety Analysis Report (UFSAR), and system drawings in order to verify the alignment of the available train was proper to support its required safety functions. The inspectors also reviewed applicable condition reports (CRs) and work orders (WO) to ensure that Entergy personnel identified and properly addressed equipment discrepancies that could impair the capability of the available equipment train, as required by 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action." The documents reviewed are listed in the
. The inspectors performed a partial walkdown of the following systems:
- 'A' core spray system when the 'B' core spray system was out of service for maintenance;
- Reactor core isolation cooling (RCIC) system when the high pressure coolant injection (HPCI) system was out of service due to emergent work;
- 'A' and 'B' low pressure injection systems and RCIC while the HPCI system was out of service for troubleshooting and repair of the steam admission valve, 23MOV-14.
These activities constituted four partial system walkdown inspection samples.
b. Findings
Introduction:
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because Entergy personnel did not maintain an adequate HELB barrier. Specifically, the inspectors identified that the HELB barrier doors between the turbine building (TB) and 'A' EDG switchgear room were open when required to be closed.
Description:
Door 76FDR-E-272-3 (door 3) is located between the TB and the 'A' EDG switchgear room and is classified as a primary HELB barrier as defined in AP-16.14, "Hazard Barrier Controls." Door 76FDR-DG-272-11 (door 11) is also located between the TB and the EDG switchgear room and is classified as a secondary HELB barrier. It is located on the same opening as door 3 on the EDG side of the wall.
On July 16, 2009, Entergy personnel conducted maintenance on door 3. To improve access to work on door 3, door 11 was opened by Entergy personnel which was contrary to the work instructions. WO 148120 work instructions required that door 11 could only be opened for "normal ingress or egress time periods without being considered a breach" and that to "ensure secondary door 76FDR-DG-272-11 is closed and operable." At approximately 09:30 AM, Entergy personnel left the work area with doors 3 and 11 open and unattended. At approximately 10:00 AM, NRC inspectors identified that the doors were open and informed the control room.
The issue was entered into Entergy's corrective action program (CAP) as CR-JAF-2009 02514. Entergy personnel restored the HELB barrier and provided training for operations, maintenance and supervisor personnel on proper work practices.
Analysis:
The inspectors identified a performance deficiency in that the primary and secondary HELB doors located between the TB and 'A' EDG switchgear room were open and unattended when the doors were required to be closed. This condition was contrary to Entergy's Hazard Barrier Control Program. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, during the timeframe that the HELB doors remained open, the reliability of the 'A' EDG subsystem to perform its safety function would be challenged during a HELB event. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency; did not represent a loss of system safety function; and did not screen as potentially risk-significant due to external initiating events.
The inspectors determined that this finding had a cross-cutting aspect in the area of human performance because Entergy supervision allowed the HELB barriers to be breached, which was inconsistent with the work instructions. (H.4(c>>
Enforcement:
10 CFR 50 Appendix B, Criterion V, "Instructions, Procedures and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
AP-16.14, "Hazard Barrier Control," Revision 4, provides requirements for maintaining a HELB barrier. Contrary to the above, Entergy personnel did not ensure that the HELB barrier was maintained in that on July 16,2009, the HELB barrier doors between the TB and 'A' EDG switchgear room were open and unattended for approximately 30 minutes.
Because the violation was of very low safety significance and it was entered into Entergy's CAP, this violation is being treated as an NCV, consistent with section VI.A.1 of the NRC Enforcement Policy. (NCV 05000333/2009004-01: HElB Barrier Doors left Open and Unattended.)
.2 Complete System Walkdown
a. Inspection Scope
The inspectors performed a complete system alignment inspection of the reactor protection system to identify discrepancies between the existing equipment lineup and the required lineup. During the inspection, system drawings and operating procedures were used to verify proper equipment alignment and operational status. The inspectors reviewed the open maintenance WOs associated with the system for deficiencies that could affect the ability of the system to perform its function. Documentation associated with open design issues such as temporary modifications, operator workarounds and items tracked by plant engineering were also reviewed by the inspectors to assess its collective impact on system operation. In addition, the inspectors reviewed the CR database to verify equipment problems were being identified and appropriately resolved.
The documents reviewed are listed in the Attachment.
These activities constituted one complete system walkdown inspection sample.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Quarterly Review
a. Inspection Scope
The inspectors conducted inspections of fire areas to assess the material condition and operational status of fire protection features. The inspectors verified, consistent with applicable administrative procedures, that combustibles and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and suppression and detection equipment were appropriately maintained; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with Entergy's fire protection program. The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 2.C.3. The documents reviewed are listed in the Attachment.
- Fire Area/Zone XVIIIRB-'1 E, elevation 227 and 242 foot;
- Fire Area/Zone XVIIIIRB-1W, elevation 227 and 242 foot;
- Fire Area/Zone IXlRB-1 A, elevation 272 foot;
- Fire Area/Zone XlRB-1 B, elevation 272 foot;
- Fire Area/Zone IAlMG-1, elevation 300 foot; and
- Fire Area/Zone VIIIIRB-1C, IXlRB-1A, elevation 300 foot.
These activities constituted six quarterly fire protection inspection samples.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
.1 Triennial Inspection
a. Inspection Scope
The inspectors reviewed Entergy's programs for maintenance, testing, and monitoring of risk significant heat exchangers (HXs) to verify whether potential HX deficiencies could mask degraded performance, and to assess the capability of the HXs to perform their design functions. The inspectors assessed whether Entergy's HX programs conformed to the station's commitments to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." In addition, the inspectors evaluated whether potential common cause heat sink performance problems could affect multiple HXs or result in an initiating event. The inspectors also reviewed operations and performance testing of the essential service water (ESW) system and ultimate heat sink (UHS). Based on risk significance and prior inspection history, the following samples were selected:
- Cresent area unit cooler (66UC-22J); and
The inspectors assessed the external condition of the HXs in the field, reviewed most recent eddy current, inspection and cleaning work results, and reviewed the applicable system heath reports to confirm that results were acceptable and that design basis assumptions for flow rate, plugged tube percentage, and heat transfer capability had been met.
The inspectors reviewed operating procedures for a loss of the service water (SW) system and loss of intake water level to determine if the instrumentation relied upon for operational decision making were available and functional. The inspectors reviewed the performance and flow balance testing of the ESW system and also reviewed the chemical treatment programs for the ESW, SW and UHS to verify that potential bio-fouling mechanisms were being addressed, including on-going treatment and monitoring as specified in the chemistry manual. The review included discussions with the ESW and SW system engineer. The documents reviewed are listed in the Attachment.
These activities constituted three triennial heat sink performance inspection samples.
b. Findings
No findings of significance were identified.
1R 11 Licensed Operator Regualification Program (71111.11)
.1 Quarterly Review (71111.11 Q - 1 sample)
a. Inspection Scope
On August 31,2009, the inspectors observed licensed operator simulator training to assess operator performance during scenarios to verify that crew performance was adequate and evaluators were identifying and documenting crew performance problems.
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. Licensed operator training was evaluated for conformance with the requirements of 10 CFR 55, "Operators' Licenses."
The documents reviewed are listed in the Attachment.
This activity constituted one operator simulator training inspection sample.
b. Findings
No findings of significance were identified .
.2 Annual Review
a. Inspection Scope
On July 14,2009, a region-based inspector conducted an in-office review of results of the licensee-administered annual operating tests for 2009. The inspection assessed whether pass rates were consistent with the guidance of the IMC 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process." The inspector verified that:
- Crew failure rate was less than 20% (Crew failure rate was 0%);
- Individual failure rate on the dynamic simulator test was less than or equal to 20%
(Individual failure rate was 0%);
- Individual failure rate on the walk-through test was less than or equal to 20%
(Individual failure rate was 0%);
- Individual failure rate on the comprehensive written exam was less than or equal to 20% (Individual failure rate was 6.2%); and
- Overall pass rate among individuals for all portions of the exam was greater than or equal to 75% (Overall pass rate was 93.8%).
b. Findings
No findings of significance were identified.
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. The reviews focused on the following aspects when applicable:
- Proper maintenance rule 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 of 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 follow systems were selected for review:
- 4.16 kilovolt (kV) electrical distribution; and
These activities constituted two quarterly maintenance effectiveness inspection samples.
b. Findings
No findings of significance were identified.
1R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)
a. Inspection Scope
The inspectors reviewed maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work. 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 documents reviewed are listed in the Attachment.
- The week of July 27,2009, which included increased risk due to multiple heavy lifts in the reactor building (RB) for the independent spent fuel storage installation (ISFSI)loading campaign, and work on 15P-2C (RB closed loop cooling pump 'C' seal replacement), 46STR-4A (SW strainer 'A' for circuit breaker repair), and 34FCV-137 (feedwater startup valve);
- The week of August 17, 2009, which included increased risk due to 'A' and 'C' EDG testing, RCIC testing and independent spent fuel storage cask heavy lifts;
- The week of August 31, 2009, which included increased risk due to independent spent fuel storage cask heavy lifts, emergent work on the HPCI system and replacement of the 'B' fuel oil transfer pump;
- The week of September 8, 2009, which included increased risk due to emergent work on the HPCI system, repair of the 'B' control rod drive system and 'B' recirculation motor generator exciter brush replacement; and
- The week of September 14, 2009, which included increased risk due to independent spent fuel storage cask heavy lifts, HPCI system testing, and a plant power reduction and increase for control rod pattern adjustment.
These activities constituted five maintenance risk assessments and emergent work control samples.
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; the use and control of applicable compensatory measures; and compliance with TSs. The inspectors' review included a verification that the operability determinations were conducted as specified by ENN-OP-104, "Operability Determinations." The technical adequacy of the determinations was reviewed and compared to the TSs, UFSAR, and associated design basis documents (DBD). The documents reviewed are listed in the
.
- CR-JAF-2009-02647, elevated HPCI system turbine casing and turbine thrust bearing oil temperature due to 23MOV-14, HPCI turbine isolation valve leakage;
- CR-JAF-2009-02924, leading edge flow meter correction factor lowering trend;
- CR-JAF-2009-02186, 'C' EDG found with a single brush tension spring dislodged from the groove in the tensioner;
- CR-JAF-2009-02509, reactor building ventilation exhaust air isolation valve, 66AOV 101B, did not close within five seconds as required; and
- CR-JAF-2009-02591, low pressure coolant injection high pump discharge pressure instrument, 1OPS-120E, with an as-found setpoint outside of the acceptance range.
These activities constituted five operability evaluation samples.
b. Findings
No findings of significance were identified.
1R18 Plant Modifications (71111.18 1 sample)
a. Inspection Scope
The inspectors reviewed permanent plant modification EC-12977, which was implemented to replace the degraded voltage timer relays, 71-27T2-1HOEB03 and 71-27T3-1HOEB03, associated with the 'B' and '0' EOG start circuits. The modification replaced the existing relays, Agastat model E7012PC and E7012PO electro-pneumatic devices, with Allen Bradley model 700-RTC 11200U 1 digital relays. The inspectors verified that the installation was consistent with the modification and design documentation; drawings and procedures were updated as applicable; and the post-installation testing was adequate.
The documents reviewed are listed in the Attachment.
This activity constituted one permanent plant modification inspection sample.
b. Findings
No findings of significance were identified.
1R 19 Post-Maintenance Testing (71111.19 - 6 samples)
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 OBOs; test instrumentation had current calibrations, adequate range, and accuracy for the application; and 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. Post-maintenance testing was evaluated for conformance with the requirements of 10 CFR 50, Appendix B, Criterion XI, "Test ControL" The documents reviewed are listed in the Attachment.
- WO 00198290, adjust 23MOV-14 torque switch setting;
- WO 00197806, repair fuel grapple;
- WO 00163719, replacement of the quad trip card of the 'F' average power range monitor;
- WO 00182075, replacement of 10P-3C, residual heat removal pump mechanical seal; and
- WO 52186644, replacement of 93P-30(M), '0' EOG turbocharger lube oil pump motor.
This inspection constituted six post-maintenance test samples.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors witnessed performance of surveillance tests (STs) and/or reviewed test data of selected risk-significant SSCs to assess whether the SSCs satisfied TSs, UFSAR, 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; test instrumentation had current calibrations, adequate range, and accuracy for the application; and tests were performed, as written, with applicable prerequisites satisfied. Upon ST completion, the inspectors verified that equipment was returned to the status specified to perform its safety function.
The following STs were reviewed:
- ST-3JB, "Core Spray Initiation Logic System 'B' Functional Test," Revision 2;
- ST-24J, "Reactor Core Isolation Cooling Flow Rate and Inservice Test," Revision 38;
These activities represented five surveillance testing inspection samples.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed simulator training activities associated with licensed operator requalification training on August 31,2009. The inspectors reviewed emergency classification declarations and notifications to ensure they were properly completed by operations personnel. The inspectors evaluated the drill for conformance with the requirements of 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." The inspectors observed Entergy staff's critique and compared their self-identified issues with observations from the inspectors' review to ensure that performance issues were properly identified. This evaluation represented one inspection sample.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
40A2 Identification and Resolution of Problems (71152 - 1 sample)
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As required by Inspection Procedure 71152, "Identification and Resolution of Problems," to identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into Entergy's CAP. The review was accomplished by accessing Entergy's computerized database for CRs and attending CR screening meetings.
In accordance with the baseline inspection procedures, the inspectors selected items across the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for additional follow-up and review. The inspectors assessed Entergy personnel's threshold for problem identification, the adequacy of the cause analyses, and extent of condition review, operability determinations, and the timeliness of the specified corrective actions.
The CRs reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
The inspectors determined that Entergy staff identified equipment, human performance and program issues at an appropriate threshold and entered them into the corrective action program .
.2 Annual Sample: Failure of 6B Feedwater Heater Level Transmitter (35LT-116B)
a. Inspection Scope
This inspection focused on Entergy staff's identification, evaluation, and resolution of degraded conditions associated with the 6B feedwater heater level transmitter (35LT 1168) as documented in CR-JAF-2009-01534. Specifically, on May 3,2009, the controlling feedwater level transmitter, 35LT-116B, failed in a low-level condition causing a high level in feedwater heater 33E-6B which resulted in isolation of extraction steam. Loss of extraction steam caused a feedwater temperature reduction and subsequently a small increase in reactor power from an indicated level of 100% to a maximum of 101.7%. The operators entered Abnormal Operating Procedure (AOP) 62, Loss of Feedwater Heating.
The operators reduced reactor power and transferred the 68 feedwater heater level control to an alternate level transmitter (35LT-1268), which responded normally to the high level in the feedwater heater.
The inspectors selected the transmitter failure issue for review because it resulted in an unplanned reactivity change and power reduction. The inspectors reviewed Entergy staff's associated root cause analysis, extent-of-condition, identification of compensatory actions, and the short-term and long-term corrective actions associated with the transmitter failure to determine if Entergy personnel had corrective actions in place commensurate with the safety significance of the issue .. The inspectors interviewed plant personnel and reviewed system health reports along with historical work orders (such as preventive maintenance and calibration history) associated with the feedwater transmitters to evaluate past performance of the transmitters and determine if Entergy staff corrected deficient conditions when identified. The inspectors also reviewed plant procedures, related industry operating experience, and the vendor manual for the level transmitters to verify appropriate deSign and operating limits were appropriately considered and evaluated, and that the level transmitters could function under design conditions. In addition, the inspectors toured accessible portions of the feedwater heater level control system to evaluate material conditions and configuration control. The documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
The inspectors found that Entergy personnel determined the high feedwater heater level condition was the result of the failure of a pneumatic level transmitter. Entergy's corrective action plan includes the troubleshooting and repair of 33LT -116B during the next refueling outage (R19). Notwithstanding, Entergy personnel determined the preventive maintenance procedure for the transmitter could be enhanced, and revised the procedure to provide technicians with more detailed instruction on inspection of components and provide acceptance criteria for replacement of components. Entergy personnel also updated the preventive maintenance strategy of the level transmitters to incorporate peri'odic replacement of internal components within the detectors.
The inspectors determined that the proposed corrective actions were reasonable with respect to the failure of the feedwater heater level transmitter. The CR package included an initial root cause evaluation, extent-of-condition reviews, completed corrective actions, planned corrective actions, and compensatory actions. The inspectors determined the proposed corrective actions were adequate to address the deficiencies identified.
Additionally, the inspectors reviewed the proposed compensatory plan developed by Entergy engineers to address the potential failure of the installed spare level transmitter currently in service (35LT-126B) for the 6B feedwater heater and found it acceptable.
Finally, the inspectors noted that several corrective actions involving repair and final failure determination of the level transmitter remain incomplete and can only be performed during an outage period.
40A3 Event Follow-up (71153 - 1 sample)
.1 (Closed) Licensee Event Report (LER) 05000333/2009007-00. Inoperable Emergency
Diesel Generators Due To Degraded Voltage Timers On July 7,2009, Entergy personnel performed surveillance testing of the 4.16 kV emergency bus degraded voltage time delay relays associated with the EDGs. The testing revealed that the delay time for three of the four relays exceeded the range permitted by TSs. This failure of both channels of the emergency onsite power system loss of power instrumentation caused both trains of the EDGs to be inoperable for longer than the time allowed by TSs. TS 3.8.1 require the plant to be in Mode 3 within 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> if both trains of EDGs are inoperable.
Entergy staffs analysis concluded that the cause of failure was due to setpoint drift characteristics that are applicable to all four of the Agastat E7012 relays used as degraded voltage timers. Entergy personnel determined the condition was reportable under 10 CFR 50.73(a){2)(i)(B) and 10 CFR 50.73(a)(2)(vii).
The inspectors reviewed this LER and determined there was a licensee-identified violation. This finding and its enforcement aspects are documented in section 40A7 of this report. This LER is closed.
40A5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that these activities were consistent with Entergy security procedures and applicable regulatory requirements. Although these observations did not constitute additional inspection samples, they were considered an integral part of the normal, resident inspectors' plant status reviews during implementation of the baseline inspection program.
b. Findings
No findings of significance were identified .
.2 Independent Spent Fuel Storage Installation
a. Inspection Scope
(60855 & 60855.1)
An independent spent fuel storage installation (ISFSI) inspection was conducted on site from July 20 through July 22, 2009, and August 31 through September 4,2009, utilizing inspection procedures (IP) 60855 and 60855.1. The ISFSllicensing basis documents and implementing procedures were reviewed as the inspection standards for the inspection.
The inspectors observed selected activities associated with loading of a dry cask canister to ensure that Technical Specifications were met and equipment operated properly. The inspectors reviewed training records to ensure personnel were properly trained. The inspectors observed work activities on the refuel floor associated with the fuel selection, loading of fuel into the cask, vacuum drying, welding, and preparations for moving of the loaded canister to the truck bay. The inspectors met with reactor engineering personnel to review the fuel selection process and associated documentation. The inspectors observed the fuel verification practices associated with the loading of cask # 11 , the second cask of the campaign. In addition, inspectors also conducted a review of the initially misplaced spent fuel bundle that occurred on July 7, 2009. The inspectors reviewed corrective actions to verify that appropriate actions were taken and that the just in-time training had been completed. The inspectors also reviewed the video recording of the fuel bundles placed into the canister to independently assess whether each bundle was placed into the proper location. A list of the documents reviewed is provided in the
.
b. Findings
No findings of significance were identified.
40A6 Meetings. Including Exit
Exit Meeting Summary
The inspectors presented the inspection results to Mr. P. Dietrich and other members of Entergy's management at the conclusion of the inspection on October 8, 2009. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified by Entergy personnel.
40A7 Licensee-Identified Violation The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a NCV.
- TS 3.3.8.1 requires that multiple independent channels of the Emergency Onsite Power System Loss of Power (LOP) instrumentation be operable to maintain operability of the emergency diesel generators. Contrary to this, on July 7, 2009, with the plant operating at 100% power (Mode 1), Entergy personnel conducted an instrument calibration on the 4.16 KV Emergency Bus Degraded Voltage Time Delay Relays, and determined that the "as-found" delay time for relays 71-27T2-1 HOEB03, 71-27T3-HOEB03, and 71-27T3-1 HOEA03, associated with the 4.16 kV emergency buses 10500 and 10600 degraded grid protection, exceeded the TS allowable values.
As a result, multiple independent channels of the Emergency Onsite Power System LOP Instrumentation were inoperable and the plant exceeded TS 3.3.8.1, Condition A completion time during the surveillance interval.
This finding was determined to be of very low safety significance (Green) because the relays and EDGs would have performed their safety functions in all cases.
Specifically, the relays remained capable of performing their safety function of allowing their associated electrical bus to swap its supply from the offsite grid to the respective on-site EDGs prior to the loss or damage of any supplied equipment. Entergy's corrective actions included the replacement of the relays in July 2009 with solid-state electronic timers and initiation of CR-JAF-2009-02397 and CR-JAF-2009-02403.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Entergy Personnel
- P. Dietrich, Site Vice President
- C. Adner, Manager Operations
- J. Barnes, Manager, Training and Development
- C. Brown, Quality Assurance Manager, Entergy
- P. Cullinan, Manager, Emergency Preparedness
- B. Finn, Director Nuclear Safety Assurance
- D. Johnson, Manager, System Engineering
- J. LaPlante, Manager, Security
- K. Mulligan, General Manager, Plant Operations
- J. Pechacek, Licensing Manager
- J. Rodriguez, Project Manager, ISFSI
- J. Solowski, Radiation Protection
- M. Woodby, Director Engineering
LIST OF ITEMS
OPEN, CLOSED, AND DISCUSSED
Opened and Closed
- 05000333/2009004-01 NCV HELB Barrier Doors Left Open and Unattended (Section 1R04)
Closed
- 05000333/2009007 -00 LER Inoperable Emergency Diesel Generators Due to Degraded voltage Timers
Discussed
None