IR 05000333/2010003
| ML102160444 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/04/2010 |
| From: | Mel Gray Reactor Projects Branch 2 |
| To: | Peter Dietrich Entergy Nuclear Northeast |
| gray, m | |
| References | |
| IR-10-003 | |
| Download: ML102160444 (31) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406*1415 August 4. 2010 Mr. Peter Site Vice President Entergy Nuclear Northeast James A FitzPatrick NIJciear Power Plant P. O. Box 110 Lycoming, NY 13093 SUBJECT: JAMES A FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000333/2010003
Dear Mr. Dietrich:
On June 30, 2010, 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 July 15, 2010, 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 self-revealing finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because the issue was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) in accordance with Section VI.A 1 of the NRC Enforcement Policy. If you contest this NCV, 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, ATTN.:
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 cross-cutting aspect aSSigned to the 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 Senior Resident Inspector at FitzPatrick. 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 http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
Sincerely,
- ,;
- !r-Projects Branch 2 Division of Reactor Projects Docket No.
- 50-333 License No.
- DPR-59 Enclosure
- Inspection Report 05000333/2010003 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ I
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SUMMARY OF FINDINGS
IR 05000333/2010003; 04/01/2010 - 06/30/2010; James A. FitzPatrick Nuclear Power Plant;
Fire Protection.
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 (IMC) 0609, "Significance Determination Process" (SOP). The cross-cutting aspect for the finding was determined using IMC 0310,
"Components Within the Cross-Cutting Areas." Findings for which the SOP 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.
Cornerstone: Mitigating Systems
- Green: A self-revealing non-cited violation (NCV) of very low safety significance of license condition 2.C(3}, "Fire Protection," was identified because Entergy personnel did not implement and maintain in effect all provisions of the approved fire protection program when multiple electrical and mechanical three hour fire barrier penetrations were not qualified to perform their required three hour fire barrier fUnction. Entergy initiated condition report (CR)-JAF-2010-01417, CR-JAF-2010-01432, CR-JAF-2010-01438, and CR-JAF-2010 01441 to address the issues, implemented fire watches as compensatory measures. poured new qualified seals, and revised maintenance procedures for installing penetration seals to explicitly describe the need to pre-mix the powder component with the liquid elastomer.
This finding is more than minor because it is associated with the protection against external events attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (I.e., core damage). Specifically, multiple fire barrier penetrations were not qualified to perform their required three hour fire barrier function and provided a barrier to fire that was less than that provided by the properly installed and qualified fire barriers. The inspectors determined the Significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix F, "Fire Protection Significance Determination Process," Phase 1. The finding was determined to be of very low safety significance (Green) because the deficiency represented a low degradation rating, since the non-qualified seals consisted of base components which had been qualified as three hour fire barriers at other nuclear facilities. The inspectors determined this finding had a cross cutting aspect in the area of human performance within the work practices component because Entergy personnel proceeded in the face of unexpected circumstances when the packaging for the kits changed and when kits were issued without a powder component (H.4(a)}. (Section 1R05)
REPORT DETAILS
Summary of Plant Status
The James A. FitzPatrick Nuclear Power Plant (FitzPatrick) began the inspection period operating at 100 percent reactor power. On April 7, 2010, operators reduced reactor power to 55 percent for the removal of the 'A' reactor feedwater pump from service to replace the inboard seal. Following repairs, operators restored power to 100 percent on April 13, 2010. 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
1R01 Adverse Weather Protection
.1 Evaluate Summer Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
The inspectors reviewed operating procedures (OPs) to verify continued availability of offsite and alternate alternating current (AC) power systems. The inspectors also reviewed Entergy's agreements and protocols established with the transmission system operator to verify that the appropriate information is exchanged when issues arise that could impact the offsite power system. The documents reviewed are listed in the
. .These activities constituted one offsite and alternate AC power systems inspection sample.
b. Findings
No findings of significance were identified .
.2 Seasonal Weather Conditions
a. Inspection Scope
The inspectors reviewed and verified completion of the warm weather preparation checklist contained in procedures AP-12.04, "Seasonal Weather Preparations," Revision 17. The inspectors reviewed the operating status ofthe reactor building and control room ventilation systems, reviewed the procedural limits and actions associated with elevated lake and air temperatures, and walked down accessible areas of the reactor building and control room to assess the effectiveness of the ventilation systems.
Discussions with operations and engineering personnel were conducted by the inspectors to ensure that plant personnel were aware of temperature restrictions ami required actions. The documents reviewed are listed in the Attachment. These activities constituted one seasonal weather conditions inspection sample.
b. Findings
No findings of significance were identified.
1R04 Eguipment Alignment
.1 Quarterly Partial System Walkdown
a. Inspection Scope
The inspectors performed three 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 func,;tions. The inspectors also reviewed applicable condition reports (eRs) and work orders (WOs) 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 Part 50, Appendix B, Criterion XVI, "Corrective Action." The documents reviewed are listed in the Attachment. The inspectors performed a partial walkdown of the following systems:
- 'A' emergency service water (ESW) system when portions of 'B' ESW system were out of service for the east crescent unit cooler supply piping chemical flush and replacement of the header drain valve, 46ESW-704B;
- 'B' emergency diesel generator (EDG) system when the 'A' EDG system was out of service to install a modification; and
These activities constituted three partial system walkdown inspection samples.
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 ArealZone III/BR-1, BR-2, IVIBR-3, BR-4, XVlIBR-5;
- Fire Area/Zone VlEG-1, EG-2, EG-5;
- Fire Area/Zone VI/EG-3, EG-4, EG-6;
- Fire Area/Zone VIIICS-1; and
- Fire Area/Zone XVlllfRB-1W.
These activities constituted five quarterly fire protection inspection samples.
b. Findings
Introduction:
A self-revealing NCV of very low safety significance of license condition 2.C(3), "Fire Protection," was identified because Entergy personnel did not implement and maintain in effect all provisions of the approved fire protection program. Specifically, multiple electrical and mechanical three hour fire barrier penetrations were poured with an elastomer that was not prepared in accordance with the required instructions and were not qualified to perform their required three hour fire barrier function.
Description:
On March 23,2010, Entergy electricians received a new kit of elastomer compound 'from the warehouse which consisted of four containers, two part 'A' containers and two part 'B' containers. Each part consisted of two containers, one with a powder and a second with a liquid, Dow Corning 170 Silicone Elastomer, which were required to be mixed prior to mixing parts 'A' and 'B' at the time of use. The two prior issuances of the kits to the electricians had included only the two containers with liquid portions, which had likewise been a change from the previously issued kits.
The manufacturer of the product, Promatec, described that a packaging change had been implemented. Previously, the Promatec 45B product was packaged in single part
'A' and 'B' six gallon pails with each part's powder contained inside a sealed plastic bag within its respective liquid filled pail. After the change, the liquid and powder portions were packaged and shipped within separate pails, two part 'A' and two part 'B.'
However, Entergy personnel determined, in March 2010, that the liquid and powder pails were separated during warehouse in-processing and only the liquid pails were issued for use in April and October, 2009. Therefore, Entergy staff identified that thirteen penetrations were poured using these issued pails which did not include the powder components. These penetrations, 8-31, 8-51, EE-378, EE-377, EE-383, EE-372, E-135, EE-367, 8-41, 8-2054, EE-358, S-4052, and.1 FK044N03, affected a range of plant areas including rooms associated with emergency service water, EDGs, cable spreading, and station batteries.
Entergy staff performed an apparent cause evaluation and determined that the electricians had inappropriately assumed that powder components were no longer required to be mixed into liquid components in those two prior issuances, and a quality control receipt inspector who was familiar with the older style packaging had inappropriately assumed that four pails did not comprise a kit when received together at the warehouse, such that these personnel did not question unexpected conditions. In addition, the apparent cause evaluation identified that maintenance procedures, IS-E-03, "Opening and Sealing of Electrical Penetrations," Revision 14, and IS-M-04, "Opening and Sealing of Non-Electrical Penetration Sleeves," Revision 10, did not include instruction or mention of powder components in the mixing and preparation of the sealing product.
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Since the electricians, in October 2009, were issued and began using two pails I
containing only liquid elastomer and, in March 2010, were issued four pails containing I liquid and powder for the same work, an adverse condition became self~revealing. In considering whether the issue was licensee identified or self revealing, the inspectors concluded the electricians did not perform deliberate or focused actions in order to identify that a change in process had taken place. However, upon identification of the readily detectable degradation within the work process, the electricians responded correctly and appropriately notified Entergy's maintenance supervision that the elastomer used to fill penetrations may have been mixed inappropriately.
Entergy entered this issue, upon identification, into their corrective action program (CR JAF-201 0-01417, CR-JAF-2010-01432, CR-JAF-201 0-01438, and CR-JAF-201 0-01441 )
and implemented compensatory measures which consisted of establishing fire watches.
Corrective actions for the thirteen affected penetrations included removing the existing elastomer and pouring new penetration seals with the proper Promatec mixture. In addition, Entergy revised maintenance procedures IS-E-03 and IS-M-04 for installing penetration seals to explicitly describe the need to pre-mix Promatec 456 powder and liquid elastomer prior to combining parts 'A' and '6' together.
Analysis:
There was a self-revealing performance deficiency in that Entergy personnel poured multiple electrical and mechanical fire barrier penetration seals with an elastomer that was not prepared in accordance with the required instructions, such that the penetration seals were not qualified to perform their required three hour fire barrier function. This finding was determined to be self-revealing because it became 5elf evident and required no active and deliberate observation to determine that a change in process had occurred when four pails were issued as a kit. in contrast to two pails being issued the previous two times. Inaddition, it was not discovered through an Entergy program or process, nor was it identified through deliberate and focused observation.
This finding is greater than minor because it is associated with the protection against external events attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the thirteen affected fire barrier penetration seals were not qualified to perform their required three hour fire barrier function and provided a barrier to fire that Was less than that provided by the qualified fire barriers.
The inspectors determined the Significance of the finding using IMC 0609, Appendix F, "Fire Protection Significance Determination Process," Phase 1. The finding was determined to be of very low safety Significance (Green) because the deficiency represented a low degradation rating. Specifically, the liquid elastomer that comprised the base components has been qualified as a three hour fire barrier at other nuclear facilities without the powder added.
The inspectors determined this finding had a cross-cutting aspect in the area of human performance within the work practices component because Entergy personnel proceeded in the face of unexpected circumstances when the packaging for the "kits changed and when kits were issued without a powder component (H.4(a)}.
Enforcement:
License condition 2.C(3) requires, in part, that Entergy shall implement and maintain in effect all provisions of the approved fire protection program. A provision
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i of the approved fire protection program is maintaining qualified three hour fire barrier penetration seals for locations S-31, S-51 , EE-378. EE-377, EE~383, EE-372, E-135, EE-367, S-41. S-2054, EE-358, S-4052, and 1FK044N03. Contrary to the above, from April 2009 until March 2010, penetration seals for locations 5-31, S-51. EE-378, EE-377, EE-383, EE-372, E-135, EE-367, S-41, 5-2054, EE-358, 5-4052, and 1FK044N03 were not qualified three hour fire barriers, due to incorrect preparation of the elastomer seal I
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material prior to installation. Because this violation was of very low safety significance and was entered into the CAP as CRs [[::JAF-2010-01417|JAF-2010-01417]], -01432, -01438, and -01441, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy.
I (NCV 05000333/2010003-01: Fire Barrier Penetrations Not Maintained as Qualified Three Hour Fire Barriers)
1R11 Licensed Operator Regualification Program
.1 Quarterly Review
a. Inspection Scope
On May 24, 2010, 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 (EOPs). 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 Part 55, "Operators' Licenses." The documents reviewed are listed in the Attachment These activities constituted one operator simulator training inspection sample.
b. Findings
No findings of Significance were noted.
.2 Biennial Review
a. Inspection Scope
The following inspection activities were performed using NUREG~ 1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and Inspection Procedure 71111.11 B, "Licensed Operator Requalification Program."
The inspectors reviewed documentation of operating history since the last requalification program inspection. The inspectors also discussed facility operating events with the resident staff. Documents reviewed included NRC inspection reports and licensee CRs that may have involved performance errors by licensed operators. These reports were reviewed to ensure that operational events and operator performance errors were not indicative of possible training deficiencies.
The inspectors reviewed four comprehensive written exams (previously administered in April 2009), nine simulator scenarios. and five job performance measures to ensure the quality of these exams met or exceeded the criteria established in the Examination Standards and 10 CFR Part 55.59.
The inspectors observed the administration of the operating exams to one crew during the onsite inspection week, which began April 26, 2010. Observations of exam administration and grading practices were conducted, including facility licensee evaluator review of final grading reports. Control of test item overlap between exam weeks was evaluated against the established criter~a for consideration of potential compromise of examination security.
Remediation practices were assessed by review of instances where operators or crews had failed either a written examination or simulator evaluation. Three instances of failed comprehensive exams were reviewed; the inspectors verified facility training staff remediated and reexamined the affected operators, where appropriate.
The inspectors observed simulator performance during the conduct of the examinations, and reviewed simulator discrepancy reports to verify facility staff were complying with the requirements of 10 CFR Part 55.46. The inspectors reviewed a sample of simulator tests including tranSient, steady state, and malfunction tests.
Conformance with operator license conditions was verified by reviewing the following records:
- Four medical records. All records were complete; restrictions noted by the doctor were reflected on the individual's license; and physical exams were given within 24 months of the last physical;
- Two license reactivation records. The records indicated the operators complied with the reactivation requirements of 10 CFR Part 55.53; and
- A sample of operator requalification attendance records. The records indicated operators attended all required courses.
On May 3, 2010. an in-office review of the final results of the operator requalffication exams was conducted. These results were for the 2010 annual operating tests; the comprehensive written exams were previously administered in April 2009. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, "Licensed Operator Requalification Performance Significance Determination Process (SOP)." The inspectors verified that:
- Crew failure rate on the dynamic simulator was less than 20%.
(Failure rate was 0%);
- Individual failure rate on the dynamic simulator test was less than or equal to 20%.
(Failure rate was 0%);
- Individual failure rate on the walkthrough test, i.e. job performance measures, was less than or equal to 20%. (Failure rate was 0%); and
- More than 75% of the individuals passed all portions of the exam (100% of the individuals passed all portions of the exam).
These activities constituted one biennial review of the licensed operator requalification program inspection sample.
b. Findings
No findings of significance were identified.
1R 12 Maintenance Effectiveness (71111.120 - 3 samples)a.
Inspection 8cope The inspectors reviewed performance-based problems involving selected in-scope structures, systems, or components (88Cs) to assess the effectiveness of the maintenance program. The documents reviewed are listed in the Attachment. The J reviews focused on the following aspects when applicable:
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- Proper maintenance rule scoping in accordance with 10 CFR Part 50.65;
- Characterization of reliability issues; Changing system and component unavailability; I
- 10 CFR Part 50.65 (a){1) and (a)(2) classifications; ,I
- Identifying and addressing common cause failures;
- Trending of system flow and temperature values;
- Appropriateness of performance criteria for 88Cs classified (a)(2); and
- Adequacy of goals and cortective actions for 8SCs classified (a)(1).
The inspectors reviewed system health reports, maintenance backlogs, and Maintenance Rule basis documents. The follow systems were selected for review:
- Reactor manual control system;
These activities constituted three quarterly maintenance effectiveness inspection samples.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
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 Part 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 April 5, 2010, which included a power reduction to 50 percent to repair the 'A' feedwater pump inboard seal;
- The week of April 12, 2010, which included planned repair on 'B' reactor building cooling heat exchanger, 'B' standby liquid control surveillance testing. 'A' recirculation generator brush replacement, 'B' recirculation exciter brush replacement, and emergent repair on the reactor manual control system for contrOl rod 30-19;
- The week of April 26, 2010, while the 'A' and 'e' EDGs were out of service for a modification installation, schedule changes due to work delay, and increased risk due to high winds and planned maintenance on the reactor coolant injection system; and
- The week of May 17, 2010, which included increased risk as a result of a downpower to 60 percent for a control rod pattern adjust and control rod testing, failure of the screen wash booster pump header isolation valve, high pressure coolant injection instrument surveillance procedures, and 'B' reactor feedwater pump control in manual.
These activities constituted four maintenance risk assessments and emergent work control inspection 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 technical specifications (TSs), The inspectors' review included verification that the operability determinations were conducted as specified by EN-OP-104, "Operability Determinations." The technical adequacy of the determinations was reviewed and compared to the TSs, UFSAR, and associated design basis documents (DBDs).
- eR-JAF-2010-01944 and CR-JAF-2010-01959, control rod 30-19 drifted from position 12 to position 14;
- eR-JAF-2010-02202, non-conforming condition associated with global nuclear fuel 2 fuel assembles;
- CR-JAF-2010-02203, 10 CFR Part 21 notification associated with electro motive diesel EDG jacket water cooling pump impeller;
- CR-JAF-2010-02331, potential slight leakage observed on the 'B' emergency service water piping in the west cable tunnel; and
- CR-JAF-2010-02557, standby liquid control pump discharge safety valve inlet flange bolt size is not consistent with design requirements.
These activities constituted five operability evaluation inspection samples.
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 DBDs; 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 Part 50, Appendix B, Criterion XI, "Test ControL" The documents reviewed are listed in the Attachment
- WO 51192203, Replace 'C' EDG manual start control relay 93-K3;
- WO 00232110. Replace 27 SOV-119E1 and 27 SOV-119E2. H2 02 monitor 'A' torus sample line valves; and
- WO 00240784, Replace the output circuit breaker associated with 71 EPA RPS1 B1 G, reactor protection system motor-generator electrical protection assembly.
These activities constituted three post-maintenance testing inspection samples.
b. Findings
No findings of significance were identified.
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R22 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 DBDs; 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-2XA, "RHR Service Water Loop A Quarterly Operability Test (1ST)," Revision 11;
- RAP-7.4.01, "Control Rod Scram Time Evaluation," Revision 24;
- ST-39B-X203A, "Type C Leak Rate Test of H2-02 Monitor A Torus Sample Line Valves (1ST)," Revision 5;
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- Automatic Actuation Test," Revision 26; ST-3PA, "Core Spray Loop A Quarterly Operability Test (1ST)," Revision 16; and I
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r These activities represented seven surveillance testing inspection samples.
b.> Findings No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
(71114.02 -1 sample)
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An onsite review was conducted to assess the maintenance and testing of the FitzPatrick alert and notification system (ANS). The Fitzpatrick ANS comprises of both sirens and tone alert radios. During the inspection, the inspectors reviewed ANS system maintenance and test records, applicable ANS procedures, and the ANS design report to ensure Entergy's compliance with design report commitments for system maintenance and testing. The inspectors also discussed the maintenance of the tone alert radios.
The inspection was conducted in accordance with NRC Inspection Procedure 71114,
of 10 CFR Part 50, Appendix E. were used as reference criteria.
These activities represented one ANS evaluation inspection sample.
b. Findings
No findings of significance were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
(71114.03 -1 sample)
The inspectors conducted a review of FitzPatrick's Emergency Response Organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO. This was performed to ensure the readiness of key licensee staff to respond to an emergency event and to ensure Entergy organizational ability to activate their emergency facilities in a timely manner. The inspectors reviewed the Fitzpatrick ERO roster, sampling of training records, call-in reports, one drive-in report, applicable procedures, and issue reports related to the ERO staffing augmentation system. The inspection was conducted in accordance with NRC Inspection Procedure 71114,
10 CFR Part 50, Appendix E, were used as reference criteria.
These activities represented one ERO staffing and augmentation system inspection sample.
b. Findings
No findings of significance were identified.
'I EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
(71114.04 -1 sample)
Since the last NRC inspection of this program area, Entergy staff implemented various changes to their Emergency Plan and Implementing Procedures. Entergy personnel had determined that, in accordance with 10 CFR Part 50.54(q), any change made to the Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR Part 50 Appendix The inspectors reviewed a sample of Emergency Plan changes, including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. No Emergency Action Level (EAL) changes were reviewed during this inspection. However, this review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 4. The req uiremenls in 10 CFR Part 50. 54(q) were used as reference criteria.
These activities represented one EAL and EP changes inspection sample.
b. Findings
No findings of significance were identified.
1EP5 Correction of Emergency Preparedness Weaknesses
a. Inspection Scope
(71114.05 - 1 sample)
The inspectors reviewed self-assessment reports and the Corrective Action Program (CAP) procedure to assess Entergy's ability to evaluate their emergency plan performance and program. The inspectors reviewed a sampling of drill reports, focused area self-assessment reports, 10 CFR Part 50.54(t) audits, quality assurance surveillances, and EP"related CRs initiated by Entergy staff at FitzPatrick from drills and audits. This inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 5. Planning standard 10 CFR Part 50.47(b)(14), and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
These activities represented one correction of emergency preparedness weaknesses inspection sample.
b. Findings
No findings of significance were identified.
'I EP6 Drill Evaluation (71114.06 1 sample}
a. Inspection Scope
The inspectors observed simulator activities associated with licensed operator requalification training on May 24, 2010. The inspectors verified that emergency classification declarations and notifications were properly completed. The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."
The inspectors observed Entergy's critique and compared Enlergy's self-identified issues with observations from the inspectors' review to ensure that performance issues were properly identified.
These activities represented one drill evaluation inspection sample.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational/Public Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
Radiological Hazard Assessment The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors verified Entergy has assessed the potential impact of these changes with respect to radiological conditions and has implemented periodic monitoring, as appropriate, to detect and quantify the associated radiological hazards.
The inspectors reviewed radiological surveys of acces~ible areas of the plant during routine plant operations. The inspectors verified that the thoroughness and frequency of the surveys were appropriate for the given radiological hazards that were accessible to workers.
The inspectors conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area, protected area, controlled area, contaminated tool storage. and contaminated machine shops).
The inspectors selected radiologically risk-significant work activities during the inspection that involved exposure to radiation that included:
- Scaffold installation in the west crescent area of the reactor building; and
- Various refueling floor outage preparation activities.
The inspectors verified that appropriate pre-work surveys were performed which were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if hazards were properly identified, including the following:
- Identification of hot particles;
- The presence of alpha emitters;
- The potential for airborne radioactive materials, including the potential presence of transuranics and/or other hard-to-detect radioactive materials;
- The hazards associated with work activities that could suddenly and severely increase radiological conditions; and
- Severe radiation field dose gradients that can result in non-uniform exposures to the body.
The inspectors selected air sample survey records and verified that samples were collected and counted in accordance with Entergy's procedures. The inspectors observed work in potential airborne areas and verified that air samples were representative of the breathing air zone. The inspectors verified that Entergy has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne.
Problem Identification and Resolution A review of related condition reports (eRs) was conducted to determine if identified problems and negative performance trends were entered into the corrective action program and evaluated for resolution.
Relevant eRs associated with the occupational radiation protection program and initiated from January 2010 through June 2010 were reviewed and discussed with Entergy's staff to determine if the follow up activities were being conducted in an effective and timely manner, commensurate with their safety significance.
Contamination and Radioactive Material Control At the radiological controlled area control point, the inspectors observed workers surveying and releasing potentially contaminated materials for unrestricted use. The inspectors verified that the counting instrumentation was located in a low background area and that the instruments' sensitivity was appropriate for the type of contamination being measured.
Instructions to Workers The inspectors selected containers holding nonexempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers, and verified that they were labeled and controlled.
The inspectors reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas (HRAs) and identified what work control instructions or control barriers had been specified. The inspectors verified that allowable stay times or permisSible dose for radiologically significant work under each RWP was clearly identified. The inspectors verified that electronic dosimeter (ED) alarm set points were in conformance with survey indications and Entergy's policy.
The inspectors selected one to two occurrences where a worker's ED noticeably malfunctioned or alarmed. The inspectors verified that workers responded appropriately to the off-normal condition. The inspectors verified that the issue was included in the corrective action program and dose evaluations were conducted as appropriate.
Radiological Hazards Control and Work Coverage During tours of the facility and review of the selected ongoing work, the inspectors evaluated ambient radiological conditions. The inspectors verified that existing conditions were consistent with posted surveys, RWPs, and worker briefings, as applicable.
During job performance observations. the inspectors verified the adequacy of radiological controls, such as required surveys, radiation protection job coverage, and contamination controls. The inspectors evaluated Entergy's means of using EDs in high noise areas as HRA monitoring devices.
The inspectors verified that radiation monitoring devices were placed on the individual's body consistent with the method that Entergy was employing to monitor dose from external radiation sources. The inspectors verified that the dosimeter was placed in the location of highest expected dose or that Entergy was properly employing an NRC approved method of determining effective dose equivalent.
For high~radiation work areas with significant dose rate gradients {a factor of 5 or more},
the inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel. The inspectors verified that Entergy's controls were adequate.
The inspectors examined Entergy's physical and programmatic controls for highly activated or contaminated materials stored within the spent fuel pool. The inspectors verified that appropriate controls were in place to preclude inadvertent removal of these materials from the pool.
The inspectors conducted selective inspection of posting and physical controls for HRAs and very high radiation areas (VHRAs), to the extent necessary to verify conformance with the Occupational PI.
These activities represented partial completion of one radiological hazard assessment and exposure controls annual inspection sample.
b. Findings
No findings of significance were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Materials Handling, Storage. and
Transportation (71124.08 - 1 Sample)
a. Inspection Scope
During the period April 12-16, 2010, the inspectors conducted the following activities to verify that Entergy's radioactive material proceSSing and transportation programs complied with the requirements of 10 CFR Part 20, 61, and 71; and Department of Transportation (DOT) regulations 49 CFR 170-189.
- The inspectors reviewed the solid radioactive waste system description in Section 11.1 - 11.3 of the UFSAR, the 2008 radiological effluent release report for information on the types and amounts of radioactive waste disposed. and the scope of Entergy's audit program to verify that it meets the requirements of 10 CFR Part 20.1101.
- The inspectors examined the radioactive waste stored in the Interim Waste Storage Facility. Stored waste was secured, controlled, and posted in accordance with 10 CFR Part 20. Storage cells were sufficiently monitored by Entergy to identify unacceptable conditions and potential unmonitored, unplanned releases, or nonconformance with waste disposal requirements. The inspectors observed numerous radwaste storage containers which were properly labeled and observed no signs of package swelling. leakage, or deformation.
- The inspectors walked-down the liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agrees with the descriptions contained in the UFSAR and in the Process Control Program; reviewed the status of any radioactive waste process equipment that is not operational and/or is abandoned in place; and verified that the changes were reviewed and documented in accordance with 10 CFR Part 50.59. as appropriate.
No changes to the equipment since the last NRC inspection of this area were identified. The inspectors reviewed the current processes for transferring and dewatering of radioactive waste resin and sludge discharges into shipping/disposal containers to determine if appropriate waste stream mixing and/or sampling procedures were used. The inspectors observed the transfer of waste condensate demineralizer bead resin and sludge from the waste collector tank. Additionally, the inspectors examined the methodology for waste concentration averaging to provide representative samples of the waste product for the purposes of waste classification as specified in 10 CFR Part 61.55 for waste disposal.
- The inspectors reviewed the radio-chemical sample analysis results for each of Entergy's radioactive waste streams (powdered reSin. bead resin. and waste sludge);reviewed Entergy's use of scaling factors and calculations with respect to these radioactive waste streams to account for difficult-to-measure radionuclides; verified th~t Entergy's program assures compliance with 10 CFR Part 61.55 and 10 CFR Part 61.56 as required by Appendix G of 10 CFR Part 20; and, reviewed Entergy's program to ensure that the waste stream composition data accounts for changing operationai parameters and thus remains valid between the annual or biennial sample analysis update.
- There were no radioactive material shipments during the inspection week of April 12, 2010, for the observation of shipment packaging preparation activities.
- The inspectors sampled the following non-excepted package shipment records and reviewed these records for compliance with NRC and DOT requirements:
- 678-JAF-2009-1308; 678-JAF-2009-1319;
- 678-JAF-2009-1327; and 678-JAF-2010-1348.
- The inspectors reviewed Entergy's licensee event reports. special reports, audits, and self-assessments related to the radioactive material and transportation programs performed since the last inspection and determined that identified problems are entered into the corrective action program for resolution. The inspectors also reviewed corrective action reports written against the radioactive material and shipping programs since the previous inspection.
These activities constituted one radioactive solid waste processing and radioactive materials handling, storage, and transportation inspection sample.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
40A1 Performance Indicator Verification (71151- 3 samples)a.
InsRection SCORe The inspectors reviewed data for the FitzPatrick EP Performance Indicators (PIs), which are:
- (1) Drill and Exercise Performance (DEP);
- (2) ERO Drill Participation; and,
- (3) ANS Reliability. The inspectors reviewed the PI data and its supporting documentation from the second quarter of 2009 through the first quarter of 2010 to verify the accuracy of the reported data. The review of these Pis was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 6.
These activities represented three performance indicator verification inspection samples.
b. Findings
No findings of significance were identified.
40A2 Identification and Resolution of Problems (71152 - 2 samples)
.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 corrective action program (CAP). The review was accomplished by accessing Entergy's computerized database for CRs and attending CR screening meetings. In accordance with the baseline im~pection procedures. the inspectors selected items across the Initiating Events, Mitigating Systems, and Barrier Integrity and Public Radiation Safety cornerstones for additional fo"ow~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.
The inspectors reviewed corrective action CRs and assessments associated with the radiation protection program that were initiated since the last inspection. The inspectors verified that problems identified by these CRs were properly characterized in Entergy's event reporting system, and that applicable cause and corrective actions were identified commensurate with the safety significance of the radiological occurrences.
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 CAP.
.2 Semiannual Review to Identify Trends (71152 ~ 1 sample)
a. Inspection Scope
As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"
the inspectors performed a review of Entergy's 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 40A2.1. The review also included issues documented in system health reports, corrective maintenance work requests, component status reports, site monthly meeting reports, and maintenance rule assessments. The inspectors' review nominally considered the six-month period of January 2010 through June 2010, although some examples expanded beyond those dates when the scope of the trend warranted. The inspectors compared and contrasted their results with the results documented in the last NRC integrated quarterly assessment report for FitzPatrick. Corrective actions associated with a sample of the issues identified in the trend report were reviewed for adequacy. The inspectors also evaluated the trend report specified in EN-Ll-102, "Corrective Action Process," and 10 CFR Part 50. Appendix B. The documents reviewed are listed in the Attachment.
These activities constituted one semiannual review inspection sample.
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 CAP .
.3 Annual Sample: Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of operator workaround conditions on the reliability, availability, potential for mis-operation of a system, and on the operators' ability to implement abnormal or emergency operating procedures. The inspectors reviewed the results of Entergy surveillance test ST-99H, "Operations Cumulative Impact Assessment," completed in May, 2010, and the resolution of items identified in the assessment. The inspectors reviewed Entergy's program for identifying operator workaround conditions at an appropriate threshold and for entering them into the corrective action program. In addition, the inspectors reviewed operating department records including standing orders for operational decision-making issues and operability evaluations.
These activities constituted one operator workaround program inspection sample.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that Entergy's corrective action program was effectively used to identify and resolve operator workaround conditions.
40A5 Other Activities
.1 Operation of an Independent Spent Fuel Storage Installation
a. Inspection Scope
An independent spent fuel storage installation (ISFSI) inspection was conducted on April 12-16, 2010, under the NRC Nuclear Material Safety and Safeguards (NMSS)inspection program, utilizing inspection procedure 60855 to review the ongoing maintenance and surveillance activities for onsite dry storage of spent fuel. The ISFSI licensing basis documents and implementing procedures were reviewed as the inspection standards for the inspection. Six loaded casks had been added to the ISFSI since the previous NRC inspection of this area. The inspection consisted of:
observation of the condition of the 15 Holtec Hi-Storm 100 casks currently storing spent fuel inside the restricted area at Fitzpatrick; independent radiation survey of the spent fuel storage casks; and review of surveillance records including annual SNM inventory I inspection, monthly air vent inspections, and recent dally air vent outlet temperature readings.
I i
These activities constituted one operation of an ISFSI inspection sample.
b. Findings
No findings of signjficance were identjfied.
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 July 15, 2010. The inspectors asked Entergy whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified by Entergy personnel.
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
- B. Sullivan, General Manager. Plant Operations
- J. Pechacek, licensing Manager
- J. Solowski, Radiation Protection
- M. Woodby, Director, Engineering
LIST OF ITEMS
OPEN, CLOSED, AND DISCUSSED
Opened and Closed
- 05000333/2010003-01 NCV Fire Barrier Penetrations Not Maintained as Qualified Three Hour Fire Barriers
Closed
None
Discussed
None