IR 05000333/2012005
ML13038A174 | |
Person / Time | |
---|---|
Site: | FitzPatrick |
Issue date: | 02/07/2013 |
From: | Burritt A L Reactor Projects Branch 2 |
To: | Colomb M J Entergy Nuclear Northeast |
References | |
IR-12-005 | |
Download: ML13038A174 (51) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PENNSYLVANIA 19406-2713 February 7, 2013 Mr. Michael Site Vice President Entergy Nuclear Northeast James A. FitzPatrick Nuclear Power Plant P. O. Box 110 Lycoming, NY 13093
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000333/2012005
Dear Mr. Colomb:
On December 31, 2012, 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 January 18, 2013, with you and 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.
The report documents two findings of very low safety significance (Green). These findings were also determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs 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 Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-
0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at FitzPatrick. In addition, if you disagree with the cross-cutting aspect assigned 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 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, 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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html the Public Electronic Reading Room).
Sincerely,/RA/ Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No.: 50-333 License No.: DPR-59
Enclosure:
Inspection Report 05000333/2012005
w/Attachment:
Supplementary Information cc w/encl: Distribution via ListServ
SUMMARY OF FINDINGS
........................................................................................................... 3
REPORT DETAILS
REACTOR SAFETY
............................................................................................................. 5 1R01 Adverse Weather Protection ................................................................................ 5
1R04 Equipment Alignment ........................................................................................... 6 1R05 Fire Protection ...................................................................................................... 7 1R11 Licensed Operator Requalification Program ........................................................ 8
1R12 Maintenance Effectiveness .................................................................................. 9
1R13 Maintenance Risk Assessments and Emergent Work Control ............................ 9
1R15 Operability Determinations and Functionality Assessments .............................. 10 1R18 Plant Modifications ............................................................................................. 11 1R19 Post-Maintenance Testing ................................................................................. 11
1R20 Refueling and Other Outage Activities ............................................................... 12
1R22 Surveillance Testing ........................................................................................... 13
RADIATION SAFETY
......................................................................................................... 14
2RS1 Radiological Hazard Assessment and Exposure Controls ................................. 14
2RS2 Occupational ALARA Planning and Controls ..................................................... 18
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
OTHER ACTIVITIES
.......................................................................................................... 20
4OA1 Performance Indicator Verification ..................................................................... 20
4OA2 Problem Identification and Resolution ............................................................... 22
4OA3 Follow-Up of Events and Notices of Enforcement Discretion ............................ 23
4OA5 Other Activities ................................................................................................... 29 4OA6 Meetings, Including Exit ..................................................................................... 38
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
.................................................................................................... A-1
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
..................................... A-1
LIST OF DOCUMENTS REVIEWED
........................................................................................ A-2
LIST OF ACRONYMS
............................................................................................................... A-9
Enclosure
- OF [[]]
- FINDIN [[]]
GS IR 05000333/2012005; 10/01/2012 - 12/31/2012; James A. FitzPatrick Nuclear Power Plant (FitzPatrick); Follow-Up of Events.
The report covered a three-month period of inspection by resident inspectors and announced
inspections performed by regional inspectors. Inspectors identified two findings of very low safety significance (Green), which were also non-cited violations (NCVs). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspects for
the findings were determined using IMC 0310, "Components Within Cross-Cutting Areas."
Findings for which the
- NRC 's program for overseeing the safe operation of commercial nuclear power reactors is described in
- NUR [[]]
EG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstone: Initiating Events Green. The inspectors identified a self-revealing, Green non-cited violation (NCV) of Technical Specification (TS) 5.4, "Procedures," because FitzPatrick personnel did not perform installation of replacement reserve station service transformers (RSSTs) 71T-2 and 71T-3 in accordance with written procedures. Specifically, station personnel did not remove
the shorting bars from the current transformer (CT) circuits, as specified by the work
instructions, which impacted trip set points for the transformer differential current protection
relays. As a result, the 71T-3 differential protection circuitry actuated after the start of a
major electrical load when it was not required, which caused a transformer lockout and loss of offsite power. As immediate corrective action, operators reestablished station power from the normal station service transformer via the 345 kilovolt (KV) back feed and secured the
emergency diesel generators (EDGs). The issue was entered into the corrective action
program (CAP) as condition report (CR)-JAF-2012-06866.
The finding was more than minor because it affected the equipment performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
The inspectors evaluated the finding in accordance with IMC 0609, Appendix G, "Shutdown
Operations Significance Determination Process." Per Attachment 1, "Shutdown Operations
Significance Determination Process Phase 1 Operational Checklists for both
BWRs," Checklist 7, "BWR Refueling Operation with RCS Level > 23'," the issue constituted a finding because, after the event, FitzPatrick did not have one operable qualified circuit
between the offsite transmission network and the onsite 1E AC electrical power distribution
subsystems. Also, per Checklist 7, this was not a finding requiring phase 2 or phase 3
analysis, nor did it constitute a loss of control event per Appendix G, Table 1. Therefore, the finding screened as very low safety significance (Green).
This finding had a cross-cutting aspect in the area of Human Performance, Resources,
because Entergy staff did not provide an accurate and up-to-date work package for
installation of the
CT shorting terminal configured with the shorting bar removed, nor did they ensure that the work package was appropriately updated with clarifying information after workers questioned the
existing instructions H.2(c). (Section 4OA3)
Enclosure Cornerstone: Mitigating Systems Green. The inspectors identified a self-revealing, Green non-cited violation (NCV) of Technical Specification (TS) 5.4, "Procedures," because Entergy did not establish and implement an adequate procedure for installation of a 4160 volt alternating current (VAC) circuit breaker. Specifically, FitzPatrick's procedure for 4160 VAC circuit breaker installation did not provide sufficient guidance to station personnel to preclude physical misalignment of
the 'A' emergency diesel generator (EDG) output breaker which occurred during installation on September 15, 2011, and resulted in failure of the breaker to close when required
following a loss of offsite power on October 5, 2012. As immediate corrective action, the 'A'
- EDG output breaker was racked out, re-aligned in the cubicle, and racked back in such that it was no longer misaligned and was flush with the front of the cubicle. An instrumented test of the 'A' and 'C'
EDGs was performed and all breakers operated correctly. The issue was
entered into the corrective action program (CAP) as condition report (CR)-JAF-2012-06868.
The finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the reliability of Division 1 EDG automatic operation was degraded for approximately one year due to the
'A' EDG breaker misalignment issue. Although the issue was identified while the plant was
shut down, the inspectors determined that it was appropriate to evaluate the condition in accordance with the at-power
- SDP because the condition existed for the previous year. In accordance with Inspection Manual Chapter (
IMC) 0609, Appendix A, "The Significance
Determination Process (SDP) for Findings At-Power," the inspectors determined that the
finding was of very low safety significance because the finding was not a design qualification
deficiency resulting in a loss of functionality or operability, did not represent an actual loss of
safety function of a system or train of equipment, and was not potentially risk significant due to external initiating events. Specifically, the 'A' EDG breaker continued to perform its safety function as evidenced by monthly surveillance tests until the misalignment condition
ultimately impacted its ability to close subsequent to October 3, 2012 testing.
The finding had a cross-cutting aspect in the area of Human Performance, Resources, because FitzPatrick personnel did not ensure that a complete, accurate and up-to-date procedure was available for 4160 VAC circuit breaker installation. Specifically, procedure
did not include steps to ensure correct alignment during breaker racking and to verify flush
alignment H.2(c). (Section 4OA3)
Enclosure
- REPORT [[]]
DETAILS Summary of Plant Status The James A. FitzPatrick Nuclear Power Plant (FitzPatrick) began the inspection period shut
down for refueling outage 20 (R20). On October 17, 2012, operators performed a reactor
startup and reached 100 percent power on October 22. On October 23, operators reduced
power to 65 percent to conduct a planned control rod pattern adjustment, and restored power to
100 percent later that day. On November 4, an uncomplicated reactor scram occurred due to an equipment problem associated with the main turbine control system. Entergy staff corrected the problem and operators performed a reactor startup on November 7. On November 9, during
power ascension with reactor power at approximately 90 percent, operators reduced power to
percent to address main condenser tube leakage conditions. Following identification and
repair, operators restored reactor power to 100 percent the following day. On November 11, an uncomplicated scram occurred due to a fire in one of the two main transformers. Following transformer replacement, operators performed a reactor startup on November 24 and reached
100 percent power on November 27. On December 2 and December 17, operators reduced
power to 75 percent to flush the main condenser water boxes due to condenser fouling. On
both occasions, operators restored reactor power to 100 percent the following day. On December 21, operators reduced power to 50 percent to address main condenser tube leakage. Following identification and repair, operators restored reactor power to 100 percent the following
day and remained at or near 100 percent power for the remainder of the inspection period.
1.
SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - 3 samples) .1 Readiness for Seasonal Extreme Weather Conditions a. Inspection Scope The inspectors performed a review of FitzPatrick's readiness for the onset of seasonal
low temperatures. The review focused on the reactor building ventilation system, the
emergency diesel generators (EDGs), and the EDG room ventilation systems. The
inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the corrective action program (CAP) to determine what temperatures or other seasonal weather could challenge these systems,
and to ensure FitzPatrick personnel had adequately prepared for these challenges. The
inspectors reviewed station procedures, including FitzPatrick's seasonal weather
preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.
Documents reviewed for each section of this inspection report are listed in the
Attachment. b. Findings No findings were identified.
Enclosure .2 Readiness for Impending Extreme Weather Conditions a. Inspection Scope On October 29, 2012, the inspectors reviewed FitzPatrick's preparations for arrival of the
remnant of Hurricane Sandy. FitzPatrick operators entered AOP-13, "High Winds,
Hurricanes and Tornadoes." The inspectors verified that the actions required by this
procedure were taken and walked down the plant exterior to identify loose or inadequately protected equipment and materials. The plant did not experience any significant operational issues as a result of the storm's passage.
On November 24, 2012, the inspectors reviewed FitzPatrick's preparations for high
winds during the reactor startup from the November 11 forced outage. The inspectors walked down exterior portions of the plant to verify that materials and equipment associated with the main transformer replacement project were adequately secured.
The inspectors verified that the circulating water system was operated in accordance
with procedural requirements for high wind conditions. The plant did not experience any
significant operational issues as a result of high winds during the plant startup. b. Findings
No findings were identified. 1R04 Equipment Alignment .1 Partial System Walkdowns (71111.04Q - 4 samples) a. Inspection Scope
The inspectors performed partial walkdowns of the following systems: 'A' standby gas treatment (SGT) during 'B'
- SGT maintenance on October 25, 2012 'B' main station battery following battery replacement during the refueling outage on November 1, 2012 'B'
EDG due to increased risk significance during the forced outage that followed the main transformer fire on November 15, 2012 'B' emergency service water (ESW) during 'A' ESW maintenance on December 13, 2012 The inspectors selected these systems based on their risk-significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors reviewed
applicable operating procedures, system diagrams, the
TSs, condition reports
(CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors performed field walkdowns of accessible
portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of
the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Entergy staff had properly
Enclosure identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization. b. Findings No findings were identified. 1R05 Fire Protection .1 Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples) a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material
condition and operational status of fire protection features. The inspectors verified that FitzPatrick personnel controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection
and suppression equipment was available for use as specified in the area pre-fire plan,
and passive fire barriers were maintained in good material condition. The inspectors
also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
North
CS-1, on December 19, 2012 b. Findings No findings were identified. .2 Fire Protection - Drill Observation (71111.05A - 1 sample) a. Inspection Scope The inspectors observed an unannounced fire brigade drill conducted on December 12, 2012, that involved a fire in the reactor water recirculation motor generator set room in the reactor building. The inspectors evaluated the readiness of the plant fire brigade to
fight fires. The inspectors verified that FitzPatrick personnel identified deficiencies,
openly discussed them in a self-critical manner at the debrief, and took appropriate
corrective actions as required. The inspectors evaluated specific attributes as follows: Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques
Enclosure Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigade's actions to determine whether these
actions were in accordance with FitzPatrick's fire-fighting strategies. b. Findings No findings were identified.
1R11 Licensed Operator Requalification Program .1 Quarterly Review of Licensed Operator Requalification Testing and Training (71111.11Q - 1 sample) a. Inspection Scope The inspectors observed licensed operator simulator training on November 13, 2012, which included a recirculating water pump trip and seal failure and a reactor feedwater
pump trip with recirculating water pump runback, and high pressure coolant injection
(HPCI) and reactor core isolation cooling (RCIC) system failures. The inspectors
evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications,
implementation of actions in response to alarms and degrading plant conditions, and the
oversight and direction provided by the control room supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document
crew performance problems. b. Findings No findings were identified. .2 Quarterly Review of Licensed Operator Performance in the Main Control Room (71111.11Q - 1 sample)
a. Inspection Scope
On October 17, 2012, the inspectors observed control room operators during the reactor startup following R20. Portions of the reactor startup, including the approach to and achievement of criticality, and heatup, were observed. The inspectors observed crew performance to verify that procedure use, crew communications, and coordination of
activities between work groups met established expectations and standards.
Enclosure b. Findings No findings were identified. 1R12 Maintenance Effectiveness (71111.12Q - 2 samples) a. Inspection Scope The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, and
maintenance rule basis documents to ensure that FitzPatrick staff was identifying and
properly evaluating performance problems within the scope of the maintenance rule. For
each sample selected, the inspectors verified that the
- SSC was properly scoped into the maintenance rule in accordance with Title 10, Code of Federal Regulations (10
CFR) Part 50.65 and verified that the (a)(2) performance criteria established by FitzPatrick
staff was reasonable. For SSCs classified as (a)(1), the inspectors assessed the
adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally,
the inspectors ensured that FitzPatrick staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. Analog Transmitter Trip System Neutron Monitoring b. Findings No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 4 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 reviewed whether 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
reviewed whether plant risk was promptly reassessed and managed. The inspectors
also walked down selected areas of the plant which became more risk significant
because of the maintenance activities to ensure they were appropriately controlled to
maintain the expected risk condition. The reviews focused on the following activities: Emergent charcoal replacement on 'B' SGT on October 25, 2012 Spent fuel pool cooling system protection measures due to lower time to boil following R20, with walkdowns performed during the week of October 29, 2012 Power ascension to 100 percent following the November 11 forced outage, a power reduction to 65 percent for a control rod pattern adjustment, high pressure coolant injection system quarterly surveillance test, and emergent maintenance to
troubleshoot a power supply problem with the 'B' rod block monitor during the week
of November 26, 2012 Power reduction to 75 percent to flush the main condenser water boxes due to
Enclosure fouling, 'B' residual heat removal (RHR) and RHR service water system quarterly surveillance tests, and a power reduction to 50 percent to support emergent
maintenance to identify and plug leaking main condenser tubes during the week of December 17, 2012 b. Findings No findings were identified. 1R15 Operability Determinations and Functionality Assessments (71111.15 - 3 samples) a. Inspection Scope The inspectors reviewed operability determinations for the following degraded or non-
conforming conditions:
SV-20A, that had exceeded their required lift test frequency on operability of the associated systems, 'D' RHR and 'A' core spray, on
September 4, 2012
- JAF -2011-04144 concerning control rod operability during startup due to channel bow considerations, on October 5, 2012
[[::JAF-2012-07728|JAF-2012-07728]], concerning 'F' safety relief valve (SRV) downward first stage temperature spikes that could be indicative of pilot valve leakage, making the SRV possibly susceptible to spurious operation, on October 25, 2012 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the
operability determinations to assess whether TS operability was properly justified and
the subject component or system remained available such that no unrecognized
increase in risk occurred. The inspectors compared the operability and design criteria in
the appropriate sections of the
UFSAR to FitzPatrick personnel's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the
measures in place would function as intended and were properly controlled by
FitzPatrick personnel. The inspectors determined, where appropriate, compliance with
bounding limitations associated with the evaluations. b. Findings
No findings were identified.
Enclosure 1R18 Plant Modifications (71111.18 - 2 samples)
.1 Temporary Modifications a. Inspection Scope The inspectors reviewed temporary modification
PT-134D Alternate Input
due to
PT-134D senses main steam line
pressure at the main turbine inlet, which is used as an input to the primary containment isolation system for automatic closure of the main steam isolation valves on low main steam line pressure with the reactor in the 'Run' mode. 29MST-1002D is a valve in the
2PT-134D sensing line that developed a steam leak. The purpose of the temporary
modification was to allow 29MST-1002D to be closed for repair while maintaining
2PT-134D operable by using an alternate input source. The inspectors verified that the design bases, licensing bases, and performance
capability of the affected system was not degraded by the modification. In addition, the
inspectors reviewed modification documents associated with the design change.
b. Findings
No findings were identified. .2 Permanent Modifications a. Inspection Scope The inspectors evaluated replacement of main transformer 71T-1A implemented by engineering change package EC 41007, "Main Transformer 71T-1A Replacement." The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the design change and the post
modification test plan. b. Findings No findings were identified. 1R19 Post-Maintenance Testing (71111.19 - 8 samples) a. Inspection Scope The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to
verify that the procedure adequately tested the safety functions that may have been
affected by the maintenance activity, that the acceptance criteria in the procedure was
consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results
adequately demonstrated restoration of the affected safety functions.
Enclosure Work Orders (WOs) 52287092, 00252161, 52288090, 00139399, 00271390, 51693751, 51693591 for work on various 'B'
- WO 52290498 to perform preventive maintenance on the 'A' outboard main steam isolation valve (MSIV),
- WO 00212935 to replace reserve station service transformer, 71T-2, deluge system, on October 3, 2012
- WO 52288695 to perform the reactor pressure vessel system leakage test following work performed in containment during R20, including control rod drive mechanism replacements, on October 11, 2012
- WO 52290673 to perform control rod scram time testing following refueling during R20, on October 11, 2012
- WO s 00152226, 00167063, 00328937 for work to correct excessive leakage from the torus purge and inert supply and isolation valves, 27
AOV-115 and -116, on October 14, 2012 WO 332252 to replace the main turbine trip solenoid valve, on November 7, 2012 b. Findings No findings were identified. 1R20 Refueling and Other Outage Activities (71111.20 - 2 samples) .1 Refueling Outage 20 (R20) a. Inspection Scope The inspectors reviewed FitzPatrick's work schedule and outage risk plan for R20, which commenced on September 16, 2012. The inspectors reviewed FitzPatrick's
implementation of outage plans and schedules to verify that risk, industry experience,
previous site-specific problems, and defense-in-depth were considered. The inspectors
observed portions of the startup process and monitored controls associated with the
following outage activities: Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable
- TS [[when taking equipment out of service Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that]]
TSs were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity
Enclosure Maintenance of secondary containment as required by TSs Refueling activities, including fuel handling and full core verification Fatigue management Containment closeout inspection Identification and resolution of problems related to refueling outage activities These activities completed one sample, which was begun last quarter when R20 commenced. b. Findings
No findings were identified. .2 November 11, 2012, Forced Outage a. Inspection Scope On November 11, 2012, the reactor automatically scrammed from approximately 100 percent power due to a failure of main transformer 71T-1A which resulted in a main generator load rejection and turbine trip. Following repair and replacement activities, the
reactor was taken critical on November 24, 2012, and placed online on November 25,
2012. The inspectors reviewed FitzPatrick staff's implementation of forced outage plans
and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. The inspectors observed portions of the cooldown, heatup, and startup processes, and monitored controls associated with the following outage activities: Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable
- TS - 5 samples) a. Inspection Scope The inspectors observed the performance of surveillance tests (]]
STs) and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied
technical specifications, the
- UFS [[]]
AR, and station procedure requirements. The
inspectors verified that test acceptance criteria were clear, tests demonstrated
operational readiness and were consistent with design documentation, test
Enclosure instrumentation had current calibrations and the appropriate range and accuracy for the application, tests were performed as written, and applicable test prerequisites were
satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following
PA, "'A' Core Spray Quarterly Operability (IST)," November 9, 2012 b. Findings No findings were identified.
2.
- RADIAT [[]]
- ION [[]]
RS1 Radiological Hazard Assessment and Exposure Controls (71124.01 - 1 sample) During the week of September 24 through 28, 2012, the inspectors reviewed and assessed FitzPatrick staff's performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR
Part 20 and guidance in Regulatory Guide (RG) 8.38, "Control of Access to High and
Very High Radiation Areas for Nuclear Plants," the
TSs as criteria for determining compliance. a. Inspection Scope Inspection Planning The inspectors reviewed FitzPatrick's 2012 performance indicators for the occupational exposure cornerstone for FitzPatrick. The inspectors reviewed the results of radiation
protection (RP) program audits. The inspectors reviewed any reports of operational
occurrences related to occupational radiation safety since the last inspection. Radiological Hazard Assessment The inspectors reviewed whether there had 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 evaluated whether FitzPatrick staff assessed
the potential impact of these changes and had implemented periodic monitoring, as
appropriate, to detect and quantify the radiological hazard. The inspectors reviewed the last two radiological surveys from the drywell, reactor building, and 'A' reactor water cleanup pump. The inspectors evaluated whether the
Enclosure thoroughness and frequency of the surveys were appropriate for the given new radiological hazard. The inspectors conducted walkdowns and independent radiation measurements in the facility, including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions. The inspectors selected the following risk-significant work activities that involved exposure to radiation. In-service inspection (ISI) inside the drywell Reactor disassembly/reassembly Safety relief valve work For these work activities, the inspectors assessed whether the pre-work surveys
performed 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 radiological hazards were properly identified (e.g., discrete radioactive hot particles, transuranics and hard to detect nuclides in air
samples, transient dose rates and large gradients in radiation dose rates). The inspectors did not observe work in potential airborne areas as there were no posted airborne radioactivity areas during the inspection period. The inspectors evaluated
whether continuous air monitors (CAMs) were located in areas with low background radiation to minimize false alarms and were representative of actual work areas. The inspectors evaluated FitzPatrick's program for monitoring levels of loose surface
contamination in areas of the plant with the potential for the contamination to become airborne. Instructions to Workers The inspectors selected three containers holding non-exempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers. The inspectors
assessed whether the containers were labeled and controlled in accordance with 10
- RWP s) used to access high radiation areas (HRAs) and evaluated if the specified work control instructions and control barriers were consistent with
HRAs. 20120512, ISI inside the drywell 20120701, reactor disassembly/reassembly 20120515, safety relief valve work
For these
- RWP s, the inspectors assessed whether allowable stay times or permissible dose for radiologically significant work under each
RWP were clearly identified. The inspectors evaluated whether Electronic Personal Dosimeter (EPD) alarm set-points were in conformance with survey indications and plant procedural requirements.
Enclosure For work activities that could suddenly and severely increase radiological conditions, the inspectors assessed FitzPatrick's means to inform workers of these changes that could
significantly impact their occupational dose. Contamination and Radioactive Material Control The inspectors observed the control point access/egress where FitzPatrick staff monitored potentially contaminated material leaving the radiological control area and
inspected the methods used for control, survey, and release of these materials from
these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors assessed whether the radiation monitoring instrumentation used for equipment release and personnel contamination
surveys had appropriate sensitivity for the type(s) of radiation present. The inspectors reviewed FitzPatrick staff's criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was guidance on how to respond to alarms that indicate the presence of licensed radioactive material. The inspectors reviewed FitzPatrick's procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors selected two sealed sources from FitzPatrick's inventory records and assessed whether the sources were accounted for and were
tested for loose surface contamination. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with10 CFR Part 20 requirements. Radiological Hazards Control and Work Coverage The inspectors evaluated ambient radiological conditions and performed independent radiation measurements during walkdowns of the facility. The inspectors assessed
whether the conditions were consistent with applicable posted surveys, RWPs, and
associated worker briefings. The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage and contamination controls. The inspectors evaluated FitzPatrick staff's use of
HRAs or
Locked High Radiation Areas (LHRAs). The inspectors assessed whether radiation monitoring devices were placed on the individual's body consistent with FitzPatrick's procedures. The inspectors assessed
whether the dosimeter was placed in the location of highest expected dose or that FitzPatrick staff properly implemented an NRC-approved method of determining effective dose equivalent. The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in high-radiation work areas with significant dose rate gradients.
Enclosure The inspectors did not review any RWPs for work within airborne radioactivity areas with the potential for individual worker internal exposures as no airborne radioactivity areas
were present during the inspection period. The inspectors examined FitzPatrick's physical and programmatic controls for highly activated or contaminated materials stored within spent fuel and other storage pools at
FitzPatrick. The inspectors assessed whether appropriate controls were in place to
preclude inadvertent removal of these materials from the pool. The inspectors examined the posting and physical controls for selected
- LHRA s and very high radiation areas (VHRAs) to verify conformance with the occupational performance indicator. Risk-Significant
- VHRA Controls The inspectors discussed with first-line health physics supervisors the controls in place for special areas that have the potential to become
- VH [[]]
RAs during certain plant
operations. The inspectors assessed whether these plant operations require communication beforehand with the health physics group, so as to allow corresponding timely actions to properly post, control, and monitor the radiation hazards including re-
access authorization. Radiation Worker The inspectors observed the performance of radiation workers with respect to stated
- RP work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the
RWP controls/limits in place, and
whether their behavior reflected the level of radiological hazards present.
RP technicians with respect to controlling radiation work. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits, and whether their behavior was consistent with their training and qualifications with respect to the
radiological hazards and work activities. Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by FitzPatrick staff at an appropriate threshold and were properly addressed for resolution in the licensee's CAP. The inspectors
assessed the appropriateness of the corrective actions for a selected sample of
problems documented by FitzPatrick staff that involve radiation monitoring and exposure controls. The inspectors assessed FitzPatrick staff's process for applying operating
experience to their plant. b. Findings No findings were identified.
Enclosure
- ALARA Planning and Controls (71124.02) The inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in
"Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be As Low As Reasonably Achievable," RG 8.10, "Operating
Philosophy for Maintaining Occupational Radiation Exposure As Low as Reasonably Achievable," the
TSs as criteria for determining compliance. a. Inspection Scope Inspection Planning The inspectors reviewed pertinent information regarding FitzPatrick's collective dose history, current exposure trends, and ongoing or planned activities in order to assess
current performance and exposure challenges. The inspectors reviewed the plant's
three year rolling average collective exposure. The inspectors compared the site-specific trends in collective exposures against the industry average values and those values from similar vintage reactors. In addition, the inspectors reviewed any changes in the radioactive source term by reviewing the trend
in average contact dose rate with recirculation piping. The inspectors reviewed site-
specific procedures associated with maintaining occupational exposures
- ALA [[]]
RA, which
included a review of processes used to estimate and track exposures from specific work
activities. Radiological Work Planning The inspectors selected the following work activities that had the highest exposure significance. 20120512,
- ISI inside the drywell 20120701, reactor disassembly/reassembly 20120515, safety relief valve work The inspectors reviewed the
ALARA work activity evaluations, exposure estimates, and exposure reduction requirements. The inspectors determined whether FitzPatrick staff
reasonably grouped the radiological work into work activities, based on historical
precedence, industry norms, and/or special circumstances. The inspectors assessed whether FitzPatrick staff's planning identified appropriate dose reduction techniques, considered alternate dose reduction features, and estimated reasonable dose goals. The inspectors evaluated whether FitzPatrick staff's
- ALA [[]]
assessment had taken into account decreased worker efficiency from use of respiratory
protective devices and/or heat stress mitigation equipment. The inspectors determined
whether FitzPatrick staff's work planning considered the use of remote technologies as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration
of
RWP documents.
Enclosure Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the current annual collective dose estimate for accuracy. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and for department and station collective dose goals. The inspectors evaluated whether FitzPatrick staff had established measures to track, trend, and if necessary, to reduce occupational doses for ongoing work activities. The
inspectors assessed whether dose threshold criteria were established to prompt additional reviews and/or additional
- ALA [[]]
RA planning and controls. The inspectors evaluated FitzPatrick staff's method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were
encountered. The inspectors assessed whether adjustments to exposure estimates were
based on sound
ALARA principles or if they were just adjusted to account for failures to plan/control the work. Source Term Reduction and Control The inspectors used FitzPatrick's records to determine the historical trends and current status of plant source term known to contribute to elevated facility collective dose. The inspectors assessed whether FitzPatrick staff had made allowances or developed contingency plans for expected changes in the source term as the result of changes in
plant fuel performance issues or changes in plant primary chemistry. Radiation Worker Performance The inspectors observed radiation worker and
- RWP compliance issues. Problem Identification and Resolution The inspectors evaluated whether problems associated with
- ALARA planning and controls are being identified by FitzPatrick staff at an appropriate threshold and were properly addressed for resolution in FitzPatrick's
CAP. The inspectors assessed FitzPatrick's process for applying operating experience to their plant.
b. Findings No findings were identified. 2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03) The inspectors verified in-plant airborne concentrations were being controlled consistent
with
- ALARA principles and the use of respiratory protection devices on-site did not pose an undue risk to the wearer. The inspectors used the requirements in 10
Enclosure "Air Sampling in the Workplace,"
TSs, and FitzPatrick's procedures required
by
- TS s as criteria for determining compliance. a. Inspection Scope The inspectors reviewed FitzPatrick's
UFSAR to identify areas of the plant designed as
potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. This review included instruments used to identify changing airborne radiological conditions such that actions to prevent an internal uptake may be taken. The inspectors reviewed reported performance indicators to identify any related
to unintended dose resulting from intakes of radioactive material. Engineering Controls The inspectors reviewed FitzPatrick staff's use of permanent and temporary ventilation to determine whether the licensee used ventilation systems as part of its engineering controls to control airborne radioactivity. The inspectors reviewed procedural guidance
for use of installed plant systems to reduce dose and assessed whether the systems were used, to the extent practicable, during high-risk activities. The inspectors selected the reactor building and the
- SGT [[system as installed ventilation systems used to mitigate the potential for airborne radioactivity. The inspectors evaluated whether the ventilation system operating parameters, were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne radioactive material area. The inspectors selected the drywell temporary ventilation system setup used to support work in contaminated areas. The inspectors assessed whether the use of the system was consistent with FitzPatrick's procedural guidance and]]
ALARA concept. The inspectors assessed whether FitzPatrick staff had established threshold criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.
b. Findings No findings were identified. 4.
- OTHER [[]]
ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1 Mitigating Systems Performance Index (5 samples) a. Inspection Scope The inspectors reviewed FitzPatrick staff's submittal of the Mitigating Systems
Performance Index (MSPI) for the following systems for the period of October 1, 2011 through September 30, 2012.
Enclosure
PI) data reported during this period, the inspectors used definitions and guidance contained in Nuclear Energy
Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator
Guideline," Revision 6, and discussed specific questions with the
- HP [[]]
CI system engineer.
The inspectors also reviewed station operator narrative logs,
- MS [[]]
PI/World Association of
Nuclear Operators (WANO)
EDG demand logs, a learning organization report (LO-HQNLO-2007-00076), and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings No findings were identified.
.2 Occupational Exposure Control Effectiveness (1 sample) a. Inspection Scope During the week of September 24 through 28, 2012, the inspectors sampled FitzPatrick submittals for the occupational radiological occurrences
PI definitions and guidance contained in the NEI 99-02, "Regulatory Assessment Performance Indicator
Guideline," Revision 6, to determine the accuracy of the
- PI for occupational radiation safety to determine if the related data was adequately assessed and reported. To assess the adequacy of FitzPatrick's
RP staff the scope and breadth of its data review and the results of those
reviews. The inspectors independently reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially
unrecognized PI occurrences. The inspectors also conducted walkdowns of numerous
locked high and very high radiation area entrances to determine the adequacy of the
controls in place for these areas.
b. Findings No findings were identified.
Enclosure
- 4OA [[2 Problem Identification and Resolution (71152 - 2 samples) .1 Routine Review of Problem Identification and Resolution Activities a. Inspection Scope As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that FitzPatrick staff entered issues into the]]
CAP at an
appropriate threshold, gave adequate attention to timely corrective actions, and
identified and addressed adverse trends. In order to assist with the identification of
repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the
CR screening meetings.
b. Findings No findings were identified.
.2 Semi-Annual Trend Review (1 sample) a. Inspection Scope The inspectors performed a semi-annual review of site issues, as required by Inspection
Procedure 71152, "Problem Identification and Resolution," to identify trends that might
indicate the existence of more significant safety issues. In this review, the inspectors
included repetitive or closely-related issues that may have been documented by
FitzPatrick personnel outside of the
CAP database for the third and
fourth quarters of 2012 to assess CRs written in various subject areas (equipment
problems, human performance issues, etc.), as well as individual issues identified during the
- 4OA 2.1). The inspectors reviewed the FitzPatrick quarterly trend report for the second quarter of 2012, conducted under
EN-LI-121, "Entergy Trending Process," to verify that FitzPatrick personnel were appropriately
evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations No findings were identified. The inspectors evaluated a sample of CRs generated over the course of the past two
quarters by departments that provide input to the quarterly trend reports. The inspectors determined that, in most cases, the issues were appropriately evaluated by Entergy staff for potential trends and resolved within the scope of the corrective action program.
However, the inspectors noted instances where issue trending had not been utilized and
may have proven useful. For example, there were multiple instances of emergency
warning siren malfunctions during the past six months, most associated with siren #4. Although the individual issues were addressed through the CAP, the inspectors did not initially see an indication that they had collectively been evaluated to determine if an
adverse trend existed. Following discussions regarding the number of siren failures,
Enclosure FitzPatrick staff initiated
[[::JAF-2012-8040|JAF-2012-8040]] to evaluate the potential adverse trend. Although the individual issues were being addressed, the inspectors considered that this
particular issue satisfied the
LI-121 definition of an adverse trend. While this was not a violation of regulatory requirements, the inspectors determined it was a missed opportunity to effectively use all of the tools available in the CAP.
.3 Annual Sample: Review of the Operator Workaround Program (1 sample) a. Inspection Scope The inspectors reviewed the cumulative effects of the existing operator workarounds,
operator burdens, operator aids and disabled alarms, and open main control room
deficiencies to identify any effect on emergency operating procedure operator actions,
and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Entergy Fleet procedure
FAP-OP-006, "Operator
Aggregate Impact Index Performance Indicator."
The inspectors reviewed FitzPatrick's process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent FitzPatrick staff
evaluations of the aggregate impact index. The inspectors also routinely tour the control
room and discuss operator workarounds with the operators to ensure the items are
addressed on a schedule consistent with their relative safety significance. b. Findings and Observations No findings were identified.
The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures. The inspectors also verified that FitzPatrick staff entered operator workarounds and
burdens into the corrective action program at an appropriate threshold and planned or
implemented corrective actions commensurate with their safety significance.
- 4OA system and]]
RHR shutdown cooling secured. The new reserve
station service transformers (RSSTs) had just been placed in service and were providing
site power. Preparations were in progress for installation of the fuel pool gates to
support cavity drain down and reactor reassembly.
At 1:01 pm, operators started the 'A' core spray pump to support testing. Immediately thereafter, a loss of offsite power occurred due to a lockout of the
- RS [[]]
STs. Operators
also received a reactor scram (all rods were already fully inserted), and the 'A' core
Enclosure spray pump shut down. All four
- EDG s automatically started and all closed in to reenergize their respective safety busses, with the exception of the 'A'
EDG, which
started but did not close in. The inspectors responded to the control room to monitor plant response and observe
operator activities. The inspectors verified that operators responded in accordance with
the applicable emergency and abnormal operating procedures. The inspectors
confirmed that the station's response was consistent with the requirements of the site
emergency plan, and that the event was reported to the
CFR Part 50.72.
b. Findings
(1) Failure to Install Reserve Station Service Transformers in Accordance with Procedure Introduction. The inspectors identified a self-revealing, Green non-cited violation (NCV) of TS 5.4, "Procedures," because station personnel did not perform installation of the
replacement
- RS [[]]
STs, 71T-2 and 71T-3, in accordance with written procedures.
Specifically, station personnel did not remove the shorting bars from the current transformer (CT) circuits, as specified by the work instructions, which impacted trip set points for the transformer differential current protection relays. Description. FitzPatrick station receives offsite electrical power from two
and 71T-3. These provide station power when the plant is shut down and when the main generator is off line. During plant operation, station electrical loads are supplied by normal station service transformer (NSST) 71T-4, which takes power from the main
generator output. In the event that neither of these sources is available, two pair of
EDGs supply
Division 1 loads through Bus 10500, and 'B' and 'D'
EC) 12703, "Replace
Reserve Station Service Transformers," which had been prepared by a contract organization. The installations were performed by contract electricians with management and oversight provided by the transformer vendor and Entergy project managers.
Enclosure The
- RSST s are provided with fault protection, in part, using a phase differential current protection scheme. Phase currents are sensed using current transformers (
CTs), which
provide reduced values of current to the protection circuit relays and other components.
RSST control panel. A conducting (shorting) bar is mounted above the shorting terminal
block, which allows individual termination points on the shorting terminal block to be
shorted by installation of screws through the shorting bar. The as-sent configuration of
the new transformers had these shorting screws installed, and the EC preparers realized
that they needed to be removed during installation of the
EC preparers instructed removal of the shorting bar itself. However, this action would result in a different
terminal configuration than was shown in the applicable EC circuit drawing, which had
not been modified to reflect the shorting bar removal and still showed the as-sent
configuration. The vendor project manager considered that the statement to remove the shorting bar
was an administrative error, and that the intent of the step was to remove the shorting
screws for the CTs that would be placed in service. Based on this interpretation, he
consulted the Entergy responsible engineer to verify which screws needed to be removed. Based on the as-sent circuit drawing in the EC, they concluded that two of the three shorting screws should remain installed. 71T-2 and 71T-3 were returned to service on October 5, 2012. At that point in the
refueling outage, site electrical requirements were so limited that the transformer
differential protection circuitry did not initially actuate, despite the incorrect CT setup. However, when operators started the 'A' core spray pump to support unrelated testing, the 71T-3 phase A differential protection relay tripped and produced a lockout of both
71T-3 and 71T-2. The EDGs automatically started and reenergized the 10500 and
10600 Busses. The loss of offsite power did not cause a loss of core or fuel pool cooling because the refueling cavity was flooded, the fuel pool gates were removed, and the decay heat
removal (DHR) system was in service. The DHR system is an alternate heat removal
system that was designed to allow RHR shutdown cooling to be secured during refueling
outages. System operation was not interrupted because it is powered from a different
offsite circuit. Nonetheless, the loss of offsite power significantly impacted the plant risk profile, which previously had been Green for all shutdown safety functions As immediate corrective action, operators reestablished station power from the
EC 12703 work instructions was a performance
deficiency that was reasonably within Entergy staff's ability to foresee and correct. The
finding was more than minor because it affected the equipment performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power
operations. The finding also was similar to example 4.b in Inspection Manual Chapter
(IMC) 0612, Appendix E, "Examples of Minor Issues," in that the error caused a
Enclosure transient. The inspectors evaluated the finding in accordance with IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process." Per Attachment 1,
"Shutdown Operations Significance Determination Process Phase 1 Operational Checklists for both
BWRs," Checklist 7, "BWR Refueling Operation with RCS Level > 23'," the issue constituted a finding because, after the event, FitzPatrick did not
have one operable qualified circuit between the offsite transmission network and the
onsite 1E AC electrical power distribution subsystems. Also per Checklist 7, this was not a finding requiring phase 2 or phase 3 analysis, nor did it constitute a loss of control
event per Appendix G, Table 1. Therefore, the finding screened as very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance, Resources,
because Entergy staff did not provide an accurate and up-to-date work package for
installation of the
CT shorting terminal configured with the shorting bar removed, nor did they ensure that the work package was appropriately updated with clarifying information after workers
questioned the existing instructions H.2(c). Enforcement.
- TS 5.4, "Procedures," states, in part, "Written procedures shall be established, implemented, and maintained covering . . . the applicable procedures recommended in
RG 1.33, Appendix A, November 1972." RG 1.33, Appendix A,
November 1972,Section I, "Procedures for Performing Maintenance," states, in part,
"Maintenance which can affect the performance of safety-related equipment should be
properly preplanned and performed in accordance with written procedures . . ." RG
1.33, Appendix A, November 1972, Section D, Procedures for Startup, Operation, and Shutdown of Safety Related BWR Systems," includes the offsite electrical system as such a system. Contrary to the above, during the 2012 FitzPatrick refueling outage, maintenance which
could affect the performance of the offsite electrical system, specifically, replacement of
- RSST s 71T-2 and 71T-3, was not properly implemented by station personnel in accordance with written procedures, in that the
CT shorting bars were not removed as
specified by the EC 12703 work instructions. As a result, on October 5, 2012, the 71T-3
phase A differential protection relay tripped in response to the start of the 'A' core spray
pump and produced a lockout of both
- RS [[]]
STs and a loss of offsite power. Because this
issue was of very low safety significance (Green) and Entergy entered it into their corrective action program as
- NRC Enforcement Policy. (NCV 05000333/2012005-01, Failure to Install Reserve Station Service Transformers in Accordance with Procedure). (2) Failure of 'A'
- EDG Output Breaker to Close Following Loss of Offsite Power Introduction. The inspectors identified a self-revealing, Green
NCV of TS 5.4, "Procedures," because Entergy did not establish and implement an adequate procedure
for installation of a 4160 volt alternating current (VAC) circuit breaker such that the
breaker was aligned properly upon installation. Specifically, FitzPatrick's procedure for
- 4160 VAC circuit breaker installation did not provide sufficient guidance to station personnel to preclude misalignment of the 'A'
EDG output breaker which occurred during
installation on September 15, 2011.
Enclosure Description. At 1:01 pm on October 5, 2012, a loss of offsite power occurred at FitzPatrick. The four
EDG) operated as expected to reenergize the 10500 Bus. Entergy's troubleshooting revealed that the 'A' EDG output breaker, 71-10502, was not properly aligned in its cubicle and thereby
prevented the normal Division I EDG starting sequence from being completed as
expected. Subsequent to the event, Entergy staff identified the top edge of the breaker
was not flush with the cubicle, but rather, protruded outward; and the breaker was not
centered in the cubicle, being flush on one side with a gap on the other, as opposed to having equal gaps on both sides.
FitzPatrick staff identified that the breaker had last been installed on September 15,
2011 when the misalignment occurred. Station personnel determined that the 'A' EDG
output breaker operated normally for approximately 12 months despite the misalignment, as supported by proper breaker operation during monthly EDG surveillance testing. However, as evidenced by the loss of offsite power event on October 5, 2012, the 'A'
EDG output breaker auxiliary contacts apparently had become disengaged due to
operationally induced vibration after the last successful operation on October 3, 2012.
The 'A'
Power Distribution," did not include steps to ensure correct alignment during breaker
racking and to verify flush alignment in the breaker cubicle following racking. The inspectors also determined that the Division I EDG remained operable but degraded until the October 3, 2012 surveillance run after which the auxiliary contacts apparently
became disengaged. The inspectors also noted that, given the operational condition at
that time, (refueling), the Division I
TS from October 2
until October 5 when the problem revealed itself. The issue was entered into the corrective action program as
[[::JAF-2012-06868|JAF-2012-06868]].
Entergy staff corrected the misalignment of the 'A' EDG output breaker and conducted
an instrumented run of the 'A' and 'C'
EDG breakers operated
correctly. FitzPatrick staff initiated a change to procedure OP-46A, "4160 V and 600 V
Normal
- AC [[Power Distribution," to include steps to ensure correct alignment during breaker racking and flush alignment in the breaker cubicle following racking. Analysis. The inspectors determined that the failure of Entergy staff to provide an adequate procedure for installation of a 4160]]
VAC circuit breaker was a performance
deficiency that was reasonably within Entergy staff's ability to foresee and correct. The finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the
reliability of Division 1 EDG automatic operation was degraded for approximately one
year due to the 'A' EDG breaker misalignment issue. Although the issue was identified
while the plant was shut down, the inspectors determined that it was appropriate to evaluate the condition in accordance with the at-power
IMC 0609, Appendix A, "The
Significance Determination Process (SDP) for Findings At-Power," the inspectors
determined that the finding was of very low safety significance (Green) because the
Enclosure finding was not a design qualification deficiency resulting in a loss of functionality or operability, did not represent an actual loss of safety function of a system or train of
equipment, and was not potentially risk significant due to external initiating events. The finding had a cross-cutting aspect in the area of Human Performance, Resources,
because FitzPatrick personnel did not ensure that a complete, accurate and up-to-date
procedure was available for 4160 VAC circuit breaker installation. Specifically,
procedure did not include steps to ensure correct alignment during breaker racking and
to verify flush alignment H.2(c). Enforcement. TS 5.4, "Procedures," states, in part, "Written procedures shall be established, implemented, and maintained covering . . . the applicable procedures
recommended in RG 1.33, Appendix A." Section I of Appendix A, "Procedures for
Performing Maintenance," states, in part, "Maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures. . ." Appendix A, Section D, "Procedures for
Startup, Operation, and Shutdown of Safety Related BWR Systems," includes
emergency power sources (e.g., diesel generator, batteries) as such a system. Contrary to the above, on September 15, 2011, maintenance which could affect the performance of the emergency diesel generators, specifically, installation of 'A' EDG
output circuit breaker 71-10502, was not properly performed, in that the written
procedure did not include steps to ensure correct alignment during breaker racking and
flush alignment in the breaker cubicle following racking. As a result, the circuit breaker
was not properly aligned such that subsequent stationary auxiliary contact disengagement resulted in failure of the breaker to automatically close when required on October 5, 2012. Because this issue was of very low safety significance (Green) and
Entergy entered it into their corrective action program as
[[::JAF-2012-06868|JAF-2012-06868]], this
finding is being treated as an
NRC Enforcement Policy. (NCV 05000333/2012005-02, Failure of 'A' EDG Output Breaker to Close Following Loss of Offsite Power) .2 November 4, 2012, Reactor Scram a. Inspection Scope On November 5, 2012, FitzPatrick was operating at approximately 100 percent power. At 9:41 pm, operators commenced main turbine testing in accordance with procedure
ST-21F, "Main Turbine Overspeed Trip Device and Mechanical Trip Valve Test." At 9:53
pm, an unexpected turbine trip and resultant reactor scram occurred. All control rods
inserted, as expected. The inspectors subsequently responded to the control room to monitor plant response
and observe operator activities. The inspectors verified that operator response was
consistent with the requirements of the site emergency plan and emergency and
operating procedures and operators properly reported the event in accordance with 10
CFR Parts 50.72 and 50.73. The inspectors also observed FitzPatrick staff's follow up actions related to the scram to ensure Entergy personnel implemented corrective actions commensurate with their safety significance before commencing the reactor startup.
Enclosure On November 7, 2012, the inspectors observed portions of the reactor startup, including the approach to and achievement of criticality at 3:56 am. The inspectors observed
operator performance to verify that the startup was performed in accordance with TSs and approved procedures. b. Findings No findings were identified.
.3 November 11, 2012, Reactor Scram and Notification of Unusual Event a. Inspection Scope At 3:55 a.m. on November 11, 2012, while operating at 100 percent power, a main turbine trip occurred which caused an automatic reactor scram. All systems responded as expected and operators stabilized plant conditions. Operators determined that the
turbine trip was in response to a fire in one of two main transformers. On-site fire
brigade personnel responded to combat the fire and assistance was requested from a
local fire department. At 5:45 a.m., the Shift Manager declared a discretionary Unusual Event (emergency action level HU6.1) due to the continuing fire. Site fire brigade and local fire department personnel succeeded in extinguishing the fire at 6:32 a.m., and the
licensee exited the UE at 8:01 a.m. The inspectors responded to the site, inspected the location of the fire, evaluated station response to the fire and the plant trip, and determined the plant was in a safe, stable condition. The inspectors verified that operators responded in accordance with the
applicable emergency and abnormal operating procedures. The inspectors confirmed
that the station's response was consistent with the requirements of the site emergency
plan, and that the event was reported to the
- NRC Region I based inspectors to evaluate the license renewal activities at FitzPatrick in accordance with
IP 71003. The inspectors performed in-plant observations of license renewal related activities and sampled
Entergy's actions for selected commitments. The bases for the review was the NRC
staff's safety evaluation report (NUREG 1905; ML080250372) issued on January 24,
2008, including Appendix A,
- JAFN [[]]
PP License Renewal Commitments, and the license
renewal application (LRA) submitted on July 31, 2006.
Enclosure b. Findings and Observations No findings were identified. In-Plant Observations The inspectors observed ongoing activities and inspected the general condition of SSCs
within the scope of license renewal. The inspectors performed reviews in the reactor
and turbine buildings, and of diesel fuel oil systems, as related to commitments and aging management programs (AMPs). The inspectors determined the general conditions to be satisfactory and Entergy's activities were in accordance with facility
programs and procedures. Commitments - Review Complete Commitment 7 - Heat Exchanger Monitoring Program
Commitment 7 stipulated that Entergy "Implement the Heat Exchanger Monitoring
Program as described in LRA Section B.1.15" by October 17, 2014. The inspectors reviewed the commitment closure verification, implementation plan, and Entergy corporate and FitzPatrick site procedures for eddy current testing and heat exchanger
monitoring, and discussed program implementation with the responsible program owner.
The inspectors concluded that Commitment 7 had been completed. Commitments Needing Additional NRC Review Commitment 1 - Buried Piping and Tanks Inspection Program
Commitment 1 stipulated that Entergy "Implement the Buried Piping and Tanks Inspection Program as described in LRA Section B.1.1" by October 17, 2014.
The inspectors reviewed the commitment closure verification, implementation plan, and
Entergy corporate and FitzPatrick site procedures for buried piping and tank inspections,
and discussed program implementation with the responsible program owner. The inspectors also reviewed the records from an excavation which inspected two buried pipes, and noted that plans existed for additional excavations prior to October 17, 2014.
The inspectors concluded that the specified buried pipe inspection before the period of
extended operations (PEO) had been completed but that additional NRC review of any
additional inspections before
NRC license renewal inspections.
Commitment 3 - Diesel Fuel Monitoring Program
Commitment 3 stipulated that Entergy "Enhance the Diesel Fuel Monitoring Program to
include periodic draining, cleaning, visual inspections, and ultrasonic measurement of the bottom surfaces of the fire pump diesel fuel oil tanks,
EDG fuel oil tanks to ensure the significant degradation is not occurring" and "specify acceptance
criteria for ultrasonic testing (UT) measurements of the diesel generator fuel storage tanks within the scope of this program."
Enclosure The inspectors reviewed the commitment closure verification, implementation plan,
calculation
CALC-12-00005 for the acceptance criteria, tank drawing, and procedures and work orders related to the tank cleaning and inspection. The inspectors discussed the program enhancements with the program owner and observed the
condition of the tanks in the plant. Also, the inspectors noted that periodic draining,
cleaning, and visual inspections have been performed on the EDG fuel oil tanks, but no
inspection of the other fuel oil tanks or UT tank measurements had been performed.
The inspectors determined that the calculated acceptance criteria appeared to be non-conservative, in that a corrosion allowance was included for some tank components but
not for others. The calculation stated that "since the design margin for the head portion
of the fuel oil storage tanks and the heads of the fire pump diesel fuel oil tank are so
restrictive, no additional [corrosion] allowance can be provided for these sections of the respective tanks." The calculation stated that "minimum measured UT values must be sent to Civil Design Engineering to determine Remaining Service Life" but no provision
was made to accomplish this expectation. Entergy issued
Corrective Action 181 to address this concern.
The inspectors noted that the acceptance criteria calculations for the fuel oil storage tanks did not address any loads due to the fuel oil delivery truck being on the concrete
pad above the underground tanks during fuel delivery. Entergy issued
LAR-2012-
00004, Corrective Action 185 to address this concern.
The inspectors reviewed the planned frequency for the cleaning and inspection of the fuel oil tanks. Safety evaluation report (SER) Section 3.0.3.2.8 documented that Entergy stated that the underground fuel oil storage tanks have been "cleaned and inspected on
an eight-year frequency" and that Entergy "proposed to continue to inspect these tanks
on this eight-year frequency based on post inspection results." Nonetheless, the
inspectors found that model work orders specified the cleaning and inspection to be done on a ten year frequency, and this frequency has not always been met. For example, Tank 93TK-6D had a cleaning and inspection on October 15, 2001, which was
almost 12 years after the previous inspection and had the next inspection scheduled for
October 21, 2013, which will be another 12 year period. Entergy issued
LAR-2012-
00004, Corrective Actions 182 and 183 to address these concerns.
The inspectors concluded that considerable progress on this commitment had been made but that additional
UT acceptance criteria should be performed during future NRC license
renewal inspections. Commitment 12 - One-Time Inspection Program
Commitment 12 stipulates that Entergy "Implement the One-Time Inspection Program as
described in LRA Section B.1.21" within the 10 years prior to October 17, 2014. The inspectors reviewed the implementation plan and Entergy corporate procedure for one-time program inspections, and discussed program implementation with the responsible program owner. The inspectors reviewed status reports, sample plans, and
records from a sample of completed inspections.
Enclosure The inspectors noted that both
SER Section 3.0.3.1.6 address the proposed one-time inspection of the main steam flow restrictors (cast austenitic
stainless steel (CASS)). Subsequent to issuance of the renewed license, Entergy determined that the flow restrictors were fabricated of a grade of
- CA [[]]
SS material which was not susceptible to cracking and removed the inspection from the sample plan. The
inspectors noted that while there was a sound technical basis for not performing the
planned inspection, Entergy had not taken any action to revise the commitment
regarding the proposed inspection. Entergy issued
LAR-2012-00004, Corrective
Action 184, to address this concern. The inspectors concluded that the One-Time Program merited additional review
following completion of the program, including the resolution of the rescinded flow
restrictor inspection.
Commitment 15 - Selective Leaching Program
Commitment 15 stipulates that Entergy "Implement the Selective Leaching Program as
described in LRA Section B.1.25" prior to October 17, 2014.
The inspectors reviewed the implementation plan and Entergy corporate procedure for selective leaching inspections, and discussed program implementation with the
responsible program owner, including a sample plan status report.
The inspectors determined that numerous selective leaching inspections were planned
for components fabricated of carbon steel, a non-susceptible material. Also, the inspectors noted that the sample plan had determined the number of samples based on material, environment and system, which represented a more extensive population of samples than proposed in FitzPatrick's
NRC guidance (i.e., sampling based on
material and environment only). Based on these observations, Entergy stated that the
sample plan for the selective leaching program would be re-evaluated and only inspections on susceptible materials would be used.
The inspectors concluded that the Selective Leaching Program merited additional NRC
review following completion of the program, including the re-evaluated sample plan.
Commitment Summary The inspectors concluded that Entergy actions on Commitment 7 were complete and
met regulatory expectations as reflected in the staff's safety evaluation report. The
inspectors concluded that additional NRC inspection was merited on Commitments 1, 3,
2, and 15. Further NRC inspection of license renewal commitments, including the above four commitments, is planned prior to the scheduled completion date of October 17, 2014.
.2 Follow-up on Alternative Dispute Resolution Confirmatory Order (92702)
Background
EA-10-248 / EA-11-106 was issued to
Entergy on January 26, 2012, to confirm commitments made to the NRC during a
mediation session held on November 9, 2011. The mediation session was conducted
Enclosure upon Entergy's request, in response to the
ADR), regarding apparent violations identified by the NRC at FitzPatrick. As part of the
settled agreement for the CO, Entergy agreed to take additional actions to ensure that the effectiveness of corrective actions previously taken for the issues identified are extended to the Entergy fleet and to the industry.
The objective of this inspection was to verify the actions required of Entergy, to date, as
documented in the CO have been implemented. The inspectors used guidance
contained in inspection procedure 92702 to conduct the reviews. Actions required of Entergy to be completed at a later date will be inspected and documented in forthcoming inspection reports.
GET) to ensure adequate coverage of the lessons learned from the
event that formed the basis for the CO, regarding both procedural compliance and the
requirement to maintain complete and accurate records in accordance with 10 CFR
50.9. (2) Findings and Observations No findings were identified. As discussed in NRC Inspection Report 05000333/2012003,
Section
CR-JAF-2012-00966 to address actions to be taken in
response to the
- GET training material content with respect to lessons learned from the events that formed the basis for the CO and concluded that
GET-PATSS, "General Employee Training Program, Entergy Fleet Specific Plant
Access Training Lesson Plan," Revision 13, did not adequately address the need for
procedural compliance and the requirement to maintain complete and accurate records in accordance with
[[::JAF-2012-00966|JAF-2012-00966]], CA 4, which were projected to be
incorporated in the lesson plan during the third quarter of 2012. The inspectors reviewed the current revision of
GET-PATSS, Revision 17, and
determined that Entergy had incorporated the recommended improvements to address the previous gaps in the
CO, highlighting the role of those who had the opportunity to
detect, report, and prevent the misconduct, as well as on the actions of the individuals
who engaged in the misconduct. The Site Vice President or General Manager for Plant
Operations at each of Entergy's nine commercial nuclear power plants will present the
case study during two station-wide meetings to ensure that both day and night shift personnel will have the opportunity to attend. Entergy will complete these presentations within 180 days of the date of the CO. Entergy will make this case study available for
NRC review before conducting these station-wide meetings.
Enclosure (2) Findings and Observations
No findings were identified. As discussed in
OA5.2, the inspectors observed case study presentations at FitzPatrick and Pilgrim Nuclear Power Station. During this inspection period, the inspectors reviewed
documentation, presented in
[[::JAF-2012-00966|JAF-2012-00966]] corrective actions 22 through 30,
confirming each Entergy nuclear site had conducted the case study presentations. This
closes item
- EN -QV-136, Nuclear Safety Culture Monitoring, which implements the safety culture monitoring processes in
- NEI 09-07 "Fostering a Strong Nuclear Safety Culture," Entergy will provide the results of its review to
NEI for its consideration in revising NEI document 09-07 "Fostering a Strong Nuclear Safety Culture." Entergy will make the results of this review
available for NRC review.
(2) Findings and Observations No findings were identified. As addressed in
[[::JAF-2012-00966|JAF-2012-00966]], CA 40, Entergy staff
performed a review of
QV-136, "Nuclear Safety Culture Monitoring," Revision 0, and
concluded that, in all likelihood, the procedure would not have detected the safety
culture weaknesses that led to the misconduct that formed the basis for the CO. Entergy
staff determined that the procedure should have a greater focus on data analysis, discussion of safety culture issues, and developing actions to address safety culture weaknesses, with less emphasis on data sorting and review. To incorporate
recommended changes Entergy staff developed revision 1 of
QV-136 which became
effective on July 11, 2012. Additionally, by letter dated August 3, 2012 (ML12229A542)
Entergy staff informed the
- 4.D. [[.3 (Closed) Temporary Instruction 2515/187 - Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns a. Inspection Scope The inspectors verified that the licensee's walkdown packages for manhole 1 and reactor building roof drains 7-9 contained the elements specified in the]]
Walkdown Guidance document.
The inspectors accompanied FitzPatrick on their walkdown of headwalls 1 and 2 and verified that the licensee performed the following: Visual inspection for indications of degradation that would prevent the functionality of the flood protection feature Critical SSC dimensions were measured Available physical margin, where applicable, was determined.
Enclosure The inspectors independently performed a walkdown of the screenwell pump house and verified that the following:
Safety-related
- SSC s and those important to safety were appropriately protected from area flooding via curbing or location above expected flood water levels The licensee followed their walkdown procedure Available physical margin was determined
CRs were written for any degraded conditions The inspectors verified that noncompliances with current licensing requirements and
issues identified in accordance with the 10 CFR 50.54(f) letter, Item 2.g of Enclosure 4, were entered into the licensee's corrective action program. In addition, issues identified in response to Item 2.g that could challenge risk significant equipment and the licensee's
ability to mitigate the consequences will be subject to additional NRC evaluation. b. Findings No findings were identified. .4 (Closed) Temporary Instruction 2515/188 - Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns a. Inspection Scope The inspectors accompanied the licensee on their seismic walkdowns of the following
equipment and walkbys of the associated areas. Seismic walkdown equipment list
(SWEL) numbers are in parentheses.
'A' spent fuel pool cooling pump (SWEL 2-8), reactor building 326 foot elevation, on September 20, 2012 'D'
- EDG building 272 foot elevation, on October 31, 2012 The inspectors independently performed walkdowns of control rod drive hydraulic control unit 02-19 water accumulator (
SWEL 1-43) and the 'A' core spray pump (SWEL 1-171)
in the reactor building (272 foot and 227 foot elevations, respectively) on November 20,
2012.
The following seismic features were verified during both the accompanied and independent walkdowns, as applicable:
Anchorage was free of bent, broken, missing or loose hardware Anchorage was free of corrosion that is more than mild surface oxidation Anchorage was free of visible cracks in the concrete near the anchors Anchorage configuration was consistent with plant documentation SSCs will not be damaged from impact by nearby equipment or structures Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment
Enclosure Attached lines have adequate flexibility to avoid damage The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding) Observations made during the walkdowns that could not be determined to be acceptable
were entered into the licensee's corrective action program for evaluation. Additionally, inspectors verified that items that could allow the spent fuel pool to drain down rapidly
were added to the
- SWEL and these items were walked down by the licensee. b. Findings No findings were identified. .5 Institute of Nuclear Power Operations (
INPO) Report Review a. Inspection Scope
The inspectors reviewed the final report for the
- IN [[]]
PO plant assessment of the James
- A. FitzPatrick Nuclear Power Plant conducted in February 2012. The inspectors reviewed this report to ensure that any issues identified were consistent with
INPO identified any significant safety issues that required further NRC follow-up. b. Findings No findings were identified.
.6 Follow-up Inspection for Three or More Severity Level
IP 92723) a. Inspection Scope The inspectors performed a follow-up inspection in accordance with inspection
procedure (IP) 92723 for three Severity Level (SL) IV Traditional Enforcement violations
in the area of potential for impacting the Regulatory Process that occurred in the second half of 2011 and first half of 2012. Consistent with guidance in IP 92723, multiple traditional enforcement violations in the same area should result in the licensee
examining the group of violations to identify any commonalities. This follow-up inspection is designed to look at the licensee's evaluation of the group of violations.
The following traditional enforcement violations were the subject of this inspection: A
- SL [[]]
- IV [[]]
CFR Part 50.73, "Licensee Event Report [LER] System," because a violation of TS 3.5.1.G for the condition of the high pressure coolant injection and
Enclosure reactor core isolation cooling systems being simultaneously inoperable was not reported to the
- SL [[]]
- IV [[]]
- CFR 50.74, "Notification of Change in Operator or Senior Operator Status," because Entergy did not notify the
- SL [[]]
- IV [[]]
- IR 2011-003; June 30, 2011) The objectives of the inspection were to determine whether Entergy personnel: Provided assurance that the causes of multiple
- SL [[]]
- IV Traditional Enforcement violations were understood Provided assurance that the extent of condition and extent of cause of multiple
- SL [[]]
- IV Traditional Enforcement violations were identified Provided assurance that corrective actions for the
- SL [[]]
IV Traditional Enforcement violations were sufficient to address the causes The inspectors reviewed condition reports, procedures, and relevant references to the violations. The inspectors also interviewed management and staff personnel who were
familiar with the violations and participated in the evaluation or corrective actions. b. Findings and Observations The inspectors determined that Entergy staff did not conduct a collective evaluation or
implement a systematic method to evaluate the group of violations to determine common causes or ascertain whether there were commonalities amongst the group of traditional
enforcement violations. Additionally, the inspectors did not identify relevant corrective action documentation that FitzPatrick personnel considered such a review or that the station's pre-inspection assessment identified or conducted this type of review. Based on a limited independent review expanded to include relevant information from
2010 through 2012, the inspectors identified two commonalities amongst the violations. Specifically, the inspectors noted that all three violations were
- NRC -identified violations (vice self-revealing and/or licensee-identified) and had aspects that potentially indicate interface weaknesses when multiple departments interact to meet required
LER reporting process). In particular,
while the inspectors did not attempt to assess whether the Licensing Department
functions were a primary or contributing cause to the NCVs, the inspectors identified that Licensing Department administrative responsibilities appeared to be involved in all three violations that impacted the regulatory process. The inspectors also identified another
prior occurrence in 2011 that would be considered to impact the regulatory processes
and similarly involved licensing department administrative responsibilities. Specifically, the inspectors noted that a minor violation regarding inaccurate
- 2011 NRC [[]]
IR) 05000333/2012002. The NRC identified the issue in 2011 (Unresolved Item
(URI) 2011004-01) and the
FAQ)
process determined that the station's omission of three down powers was not correct or
consistent with PI reporting guidance.
Enclosure Overall, the inspectors concluded that Entergy did not meet the inspection objectives of
- NRC [[]]
IP 92723. However, the inspectors did not identify a regulatory violation or
standard that was not met. The results of this inspection may be considered by the
- NRC in evaluating and dispositioning future traditional enforcement violations that impact the regulatory process or have similar performance aspects. Entergy staff issued
CR-JAF-
2012-08880 to address these observations. 4OA6 Meetings, Including Exit On January 18, 2013, the inspectors presented the inspection results to Mr. Michael Colomb, Site Vice President, and other members of the FitzPatrick staff. The inspectors
verified that no proprietary information was retained by the inspectors or documented in
this report.
- ATTACH [[]]
- MENT [[:]]
- SUPPLE [[]]
- INFORM [[]]
- SUPPLE [[]]
- INFORM [[]]
- ATION [[]]
- KEY [[]]
- POINTS [[]]
- OF [[]]
CONTACT Entergy Personnel
M. Colomb, Site Vice President
C. Adner, Manager, Licensing
C. Brown, Manager, Quality Assurance, Entergy B. Finn, Director, Nuclear Safety Assurance T. Hunt, Manager, Corrective Action and Assessment
K. Irving, Manager, Programs and Components Engineering
D. Poulin, Manager, Operations
T. Redfearn, Manager, Security M. Reno, Manager, Maintenance E. Riley, License Renewal Project Manager
B. Sullivan, General Manager, Plant Operations
- LIST [[]]
- OF [[]]
- ITEMS [[]]
- DISCUS [[]]
- AND [[]]
UPDATED
Opened/Closed 05000333/2012005-01 NCV Failure to Install Reserve Station Service Transformers in Accordance with Procedure
(Section 4OA3)05000333/2012005-02
EDG Output Breaker to Close Following Loss of Offsite Power (Section 4OA3)
05000333/2515/187
OA5)
05000333/2515/188
OA5)
Attachment
- LIST [[]]
- OF [[]]
- DOCUME [[]]
- NTS [[]]
- REVIEW [[]]
ED Section 1R01: Adverse Weather Protection Procedures AOP-13, "High Winds, Hurricanes and Tornadoes," Revision 19
- OP -21, "Emergency Service Water," Revision 38 OP-22, "Diesel Generator Emergency Power," Revision 58
VDC Power System," Revision 27 Section 1R05: Fire Protection
Procedures
RPT-04-00478, "JAF Fire Hazards Analysis," Revision 2
Section 1R11: Licensed Operator Requalification Program
- OP -65, "Startup and Shutdown Procedure," Revision 114 Section 1R12: Maintenance Effectiveness Procedures
DC-206, "Maintenance Rule (a)(1) Process," Revision 2
Attachment Documents
- APL -12-002, Maintenance Rule (a)(1) Action Plan for the Analog Transmitter Trip System, Revision 0 System Health Report for 02-3 - Nuclear Boiler Instrumentation, third quarter 2012
- RPT -NMS-02278, "Maintenance Rule Basis Document System 07 Neutron Monitoring" System Health Report for Neutron Monitoring System for fourth quarter 2011 through third quarter 2012 Work Orders WO 302288
- WO [[]]
Condition Reports
- JAF -2012-08347Section 1R13: Maintenance Risk Assessments and Emergent Work Control AP-10.10, "On-Line Risk Assessment," Revision 8
WM-104, "On Line Risk Assessment," Revision 7
Section 1R15: Operability Determinations and Functionality Assessments Procedures
RE-216, "Channel-Control Blade Interference Monitoring," Revision 2 RAP-7.3.39, "Channel - Control Blade Interference Monitoring," Revision 2
Documents
- NE -11-00080, "FitzPatrick C20 Channel-Control Blade Interference Monitoring Plan," Revision 2 Operability Evaluation for
[[::JAF-2011-04144|JAF-2011-04144]]
Attachment Section 1R19: Post Maintenance Testing Procedures
MP-002.04, "Reactor Vessel Safety/Relief Valve (SRV) Maintenance (IST), Revision 36
MSIV Fast Closure Test (IST)," Revision 25
ISI)," Revision 30
Documents
[[::JAF-2012-07674|JAF-2012-07674]] WO 277786
Section 1R20 Refueling and Other Outage Activities
Procedures
RHR-Shutdown Cooling," Revision 24
OP-30A, "Refueling Water Level Control," Revision 16
OP-65, "Startup and Shutdown Procedure," Revisions 113 and 114
OSP-66.001, "Management of Refueling Activities," Revision 2 Documents R20, "Schedule Risk Assessment Based on Schedule Issued 8/6/12, dated 9/15/12," Revision 1
Section 1R22: Surveillance Testing Condition Reports
JAF-2012-07282Section 2RS1: Radiological Hazard Assessment and Exposure Controls
Procedures
RP-121, "Radioactive Material Control," Revision 6 Surveys Reviewed [[::JAF-1209-0599|JAF-1209-0599]], 9/27/12
[[::JAF-1209-0563|JAF-1209-0563]], 9/26/12
[[::JAF-1209-0470|JAF-1209-0470]], 9/24/12 [[::JAF-1209-0522|JAF-1209-0522]], 9/24/12
[[::JAF-1209-0347|JAF-1209-0347]], 9/20/12 [[::JAF-1209-0339|JAF-1209-0339]], 9/20/12
[[::JAF-1209-0326|JAF-1209-0326]], 9/20/12 [[::JAF-1209-0322|JAF-1209-0322]], 9/20/12
[[::JAF-1209-0309|JAF-1209-0309]], 9/19/12 [[::JAF-1209-0291|JAF-1209-0291]], 9/19/12
[[::JAF-1209-0284|JAF-1209-0284]], 9/19/12 [[::JAF-1209-0273|JAF-1209-0273]], 9/18/12
[[::JAF-1209-0264|JAF-1209-0264]], 9/18/12
[[::JAF-1209-0279|JAF-1209-0279]], 9/18/12
Attachment
[[::JAF-2012-05595|JAF-2012-05595]]
Section:
EN-RP-131, "Air Sampling," Revision 9
Air Samples Reviewed
Sampler Number Survey Number Date 1146 120125 9/19/12 1115 120225 9/25/12
1114 120226 9/25/12
1114 120227 9/25/12
Section 4OA2: Identification and Resolution of Problems
Procedures
[[::JAF-2012-04455|JAF-2012-04455]]
Attachment
[[::JAF-2012-7901|JAF-2012-7901]] OP-11A, "Main Generator, Transformers and Isolated Bus Phase Cooling," Revision 43
OP-65, "Startup and Shutdown Procedure," Revision 114
ST-22F, "Main Turbine Overspeed Trip Device and Mechanical Trip Valve Test," Revision 8
Section
EN-QV-136," dated August 3, 2012
Commitment 1 (Buried Piping and Tanks) A-18341, "Commitment Closure Verification Form," April 27, 2012
EN-DC-343, "Underground Piping and Tank Inspection and Monitoring Program," Revision 4 B12UT016, "UT Examination of 10" CST yard piping," August 1, 2012
B12UT017, "UT Examination of 12" CST yard piping," August 1, 2012
Buried Piping General Visual Inspection - 10"CST yard piping, August 1, 2012
Attachment Buried Piping General Visual Inspection - 12"CST yard piping, August 1, 2012 LinTec, Underground Piping Inspection - 10"
HPCI, August 6, 2012
LinTec, Underground Piping Inspection - 12"
LAR-2012-00004, Corrective Action 186
Commitment 3 (Diesel Fuel) A-18345, "Commitment Closure Verification Form," May 3, 2012
RPT-09-LR009, "Diesel Fuel Monitoring AMP Implementation," Revision 0
Calculation
- CAL -12-00005, "Required Wall Thickness for Fuel Oil Storage Tanks, Fuel Oil Day Tanks, and Fire Pump Diesel Oil Tank," Revision 0 Drawing 11825-FV-17A, "Fuel Oil Storage Tanks; 93-TK-6A,-6B,-6C, and -6D," Revision 4
WM-105, "Clean and inspect EDG day tank"
Model
- UT [[]]
WM-105-00, Clean and inspect fuel oil tank
Record of diesel fuel oil storage tank cleanings/VT available through electronic search, October 3,
- LAR -2012-00004, Corrective Actions 181, 182, 183, 185 Commitment 7 (Heat Exchangers) A-18349, "Commitment Closure Verification Form"
Commitment 12 (One-Time Inspection)
- 0 JAF [[]]
OTI Status Report, October 1, 2012 Completed One-Time Inspections, October 1, 2012
Remaining One-Time Inspections, October 1, 2012
EDG fuel oil duplex filters 4C and 5C
Commitment 15 (Selective Leaching) A-18357, "Commitment Closure Verification Form," April 7, 2012
FAP-LR-025, "Selective Leaching Inspection," Revision 3
Leaching
NRC Inspection Report 05000333/2011-004
NRC Inspection Report 05000333/2011-005
AC - EDG (September 2011 - August 2012) and associated station narrative logs
Attachment Selected
- WANO [[]]
- WANO [[]]
HQNLO-2007-0076, Corrective Action 11
Attachment
- LIST [[]]
- OF [[]]
- ACRONY [[]]
- ALA [[]]
BWR boiling water reactor CA corrective action
CAM continuous air monitor
CO confirmatory order CR condition report
CST condensate storage tank
EC engineering change EDG emergency diesel generator
Entergy Entergy Nuclear Northeast
EPD electronic personal dosimeter
- HP [[]]
CI high pressure coolant injection
INPO Institute of Nuclear Power Operations IP inspection procedure
- LH [[]]
- MS [[]]
NCV non-cited violation NEI Nuclear Energy Institute
- NS [[]]
- PA [[]]
PI performance indicator PMT post-maintenance test
PWR pressurized water reactor
Attachment R20 refueling outage
- RS [[]]
ST reserve station service transformer
RWP radiation work permit
SGT standby gas treatment SL severity level
- UFS [[]]
AR updated final safety analysis report
- VH [[]]
- WA [[]]
NO World Association of Nuclear Operators