IR 05000333/2014003
| ML14224A014 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/08/2014 |
| From: | Arthur Burritt Reactor Projects Branch 2 |
| To: | Coyle L Entergy Nuclear Northeast |
| Burritt A | |
| References | |
| IR-14-003 | |
| Download: ML14224A014 (41) | |
Text
ugust 8, 2014
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000333/2014003
Dear Mr. Coyle:
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed inspection report documents the inspection results, which were discussed on July 17, 2014, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one violation of NRC requirements, which was of very low safety significance (Green). However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violation in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at FitzPatrick. In addition, if you disagree with the cross-cutting aspect assigned to the finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at FitzPatrick.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs 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 05000333/2014003 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-333 License No. DPR-59 Report No. 05000333/2014003 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, NY Dates: April 1, 2014, through June 30, 2014 Inspectors: E. Knutson, Senior Resident Inspector B. Sienel, Resident Inspector J. Furia, Senior Health Physicist R. Latta, Senior Reactor Inspector R. Rolph, Health Physicist Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
IR 05000333/2014003; 04/01/2014 - 06/30/2014; James A. FitzPatrick Nuclear Power Plant (FitzPatrick); Radioactive Material Handling, Storage, and Transportation.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified one finding of very low safety significance (Green) which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Public Radiation Safety
- Green.
The inspectors identified a Green NCV of 10 CFR 71.5, Transportation of Licensed Material, and 49 CFR 172, Subpart I, Safety and Security Plans. Specifically, Entergy personnel shipped a radioactive quantity of category 2 Radioactive Material in Quantities of Concern (RAM-QC) on the public highways to a waste processor without adhering to its transportation security plan. Prior to shipment, Entergy staff failed to recognize that the quantity of radioactive material met the definition of RAM-QC. Entergy staff entered this issue into their corrective action program (CAP) as condition report (CR)-JAF-2014-02337.
The issue was more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety cornerstone and affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. In accordance with IMC 0609, Appendix D,
"Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because Entergy had an issue involving transportation of radioactive material, but it did not involve: (1) a radiation limit exceeded; (2)a breach of package during transport; (3) a certificate of compliance issue; (4) a low level burial ground nonconformance; or (5) a failure to make notifications or provide emergency information. This finding had a cross-cutting aspect in the area of Human Performance,
Work Processes, in that the documentation (procedures) to support this activity was inadequate [H.7]. (Section 2RS8)
REPORT DETAILS
Summary of Plant Status
FitzPatrick began the inspection period at 100 percent power. On April 6, 2014, operators reduced power to 50 percent to address main condenser tube leakage. Operators further utilized the period of reduced power operations to perform single control rod scram time testing, channel-control blade interference testing, and a control rod sequence exchange. Following completion of these activities and identification and repair of the main condenser tube leak, operators restored power to 100 percent on April 8, 2014. On seven other occasions (April 23, May 4, May 7, May 30, twice on June 11, and June 15), operators performed similar short duration power reductions to 40-50 percent to address main condenser tube leakage. On June 1, 2014, operators commenced a reactor shutdown due to a more significant condenser tube leak. Following repairs, operators performed a reactor startup on June 3, 2014. Operators held power at approximately 50 percent to address additional condenser tube leaks, then proceeded with power ascension, reaching 100 percent power on June 6, 2014. On June 16, 2014, operators reduced power to 50 percent to address main condenser tube leakage. However, on this occurrence, operators left one of the three circulating water pumps secured in an attempt to reduce the frequency of condenser tube leaks. Operators increased power until limited by turbine/condenser parameters at approximately 85 percent power and continued to operate there for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors reviewed Entergys preparations for the onset of seasonal high temperatures. The review focused on the control room ventilation and reactor building ventilation systems. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors reviewed station procedures including Entergys 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 hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems
a. Inspection Scope
The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power systems to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergys procedures affecting these areas and the communications protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Entergy established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system engineer, reviewing CRs and walking down portions of the offsite and AC power systems including the 115 kilovolt (kV) switchyard.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdown (71111.04 - 5 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
B and D emergency diesel generators (EDGs) due to increased risk significance while A and C EDGs were inoperable because of an emergent failure of their output cross-tie circuit breaker on April 1, 2014 B standby liquid control (SLC) system due to increased risk significance during planned maintenance on the A SLC system on April 22, 2014 B core spray system due to increased risk significance during planned maintenance on the A core spray system on April 23, 2014 A and B 125 volt direct current (VDC) electrical systems due to increased risk significance during planned maintenance on the C EDG on May 20, 2014 A residual heat removal service water (RHRSW) system due to increased risk significance during planned maintenance on the B RHRSW system on June 10, 2014 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 UFSAR, TSs, 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 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
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 Entergy 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.
Reactor building west crescent area, fire area/zone XVII/RB-1W, on April 24, 2014 West cable tunnel, fire area/zone IC/CT-1, on May 5, 2014 A train EDG and switchgear rooms, fire areas/zones V/EG-1, EG-2, and EG-5, on May 12, 2014 B train EDG and switchgear rooms, fire areas/zones V/EG-3, EG-4, and EG-6, on May 23, 2014 West electric bay, fire area/zone IC/SW-1 on May 28, 2014
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review (1 sample)
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, the FitzPatrick Individual Plant Examination, and the Individual Plant Examination of External Events to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if Entergy staff identified and corrected potential flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the screenwell to verify adequate separation between lake level and safety and non-safety related lake water pump motors.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on June 10, 2014, which included the use of abnormal operating procedures for security-related events, a loss of offsite power, and a reactor scram with offsite power still not available. 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 crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
On April 23, 2014, the inspectors observed operator performance during an unplanned power reduction to 40 percent to address main condenser tube leakage. Operator actions included the manipulation of reactivity by control rod insertion and reactor water recirculation system flow reduction. The inspectors observed crew performance to verify that procedure use, crew communications, and coordination of activities between work groups met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
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 Entergy 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 10 CFR 50.65 and verified that the (a)(2)performance criteria established by Entergy 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 Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
115 kV Distribution Emergency Lighting
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work. The inspectors 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 maintenance on the A and C EDG output cross-tie circuit breaker after failing a surveillance the week of April 1, 2014 Planned high pressure coolant injection (HPCI) system maintenance the week of April 7, 2014 Planned sequential A standby gas treatment (SBGT), A core spray, and A SLC system maintenance windows and an emergent down power to 40 percent to address main condenser tube leakage the week of April 21, 2014 Planned C EDG maintenance the week of May 20, 2014 Planned A 125 VDC main station battery charger maintenance and a control rod adjustment the week of May 26, 2014 Emergent maintenance to respond to a ground on the A 125 VDC electrical system and two emergent power reductions to 50 percent to address main condenser tube leakage the week of June 9, 2014
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
CR-JAF-2014-01575 concerning operability of the B emergency service water (ESW)and RHRSW pumps when the B safety-related pump room vent fan phase B overload tripped while the A and C EDGs were already inoperable on April 1, 2014 CR-JAF-2014-02040 concerning the operability of HPCI with a 1-2 gallon per minute service water leak from unit cooler 66UC-22K, which is located above the HPCI system, on April 23, 2014 CR-JAF-2014-02571 concerning the receipt of several alarms for the C EDG following shutdown of the C EDG as a part of monthly surveillance testing, and their implications for EDG operability on May 21, 2014 CR-JAF-2014-02471 concerning the operability of snubbers that were tested with snubber test machines that had been calibrated by an unqualified supplier on June 2, 2014 CR-JAF-2014-02863 concerning control rod movement deficiencies that occurred during reactor startup after the June 1-3 forced outage and their impact on reactivity control system operability on June 6, 2014 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 TSs and UFSAR to Entergy staffs 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 Entergy staff. The inspectors determined compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The normal station service transformer (NSST) 71T-4 supplies station loads during plant operations at power. Temporary Modification Engineering Change (EC) 45213, Temporarily Jumper 71MOD-10001, was developed to temporarily jumper the NSST motor operated disconnect switch, 71MOD-10001, due to damage that occurred to the switch when an attempt was made to reenergize the NSST while the disconnect switch was not fully closed. Rather than jumpering the switch, Entergy staff subsequently determined that damage to the existing switch could be restored to a condition such that the normally motor operated switch would operate satisfactorily if it were manually closed and then disabled in the closed position. The inspectors reviewed the 10 CFR 50.59 documentation and reviewed the EC to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capabilities of the 115 kV electrical distribution system.
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The decay heat removal system provides an alternate means of heat removal from the spent fuel pool (SFP) and the reactor when the vessel head is removed, the reactor cavity is flooded, and the fuel transfer gates are removed. It is normally used during refueling outages to allow residual heat removal (RHR) shutdown cooling to be secured for maintenance on suction line components. The system utilizes a primary loop which passes SFP water through two frame-and-plate heat exchangers and returns it to the SFP, and a secondary loop which provides cooling water to the heat exchangers, with cooling provided by two forced draft cooling towers. To prevent contamination of the secondary loop in the event of a heat exchanger leak, the secondary loop is operated at a higher pressure than the primary loop. As designed, the system included an automatic trip of the primary pump in the event that secondary-to-primary differential pressure dropped to 3 psid. However, this feature was evaluated as being unnecessary, given the high reliability of frame-and-plate heat exchangers and because higher pressure in the secondary loop would normally preclude contamination by leakage from the primary loop.
EC 48365, Change 32DPS-105 from a Trip/Alarm Function to an Alarm Only Function, was developed to eliminate unnecessary losses of the decay heat removal function due to actuation of this feature. 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, including the 10 CFR 50.59 screening and documentation, and discussed the modification with site design and system engineering staff.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests 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.
Work order (WO) 00352058 to repair a leak on the A SLC pump on April 22, 2014 WO 52251190 to perform preventive maintenance on the A core spray discharge to reactor outboard isolation valve (14MOV-11A) motor on April 23, 2014 WO 52489116 to replace electrolytic capacitors in the A core spray instrument power supply on April 23, 2014 WO 52349468 to perform preventive maintenance on the SBGT suction from HPCI gland seal exhauster isolation valve (01-125MOV-13A) operator on April 24, 2014 WO 52489775HA1 to inspect ESW strainer 46STR-5B2 on May 12, 2014 WO 00342650 for preventive maintenance on the RHRSW-A to RHR cross tie upstream isolation valve, 10MOV-148A, on June 18, 2014
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and station procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the 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 surveillance tests:
ST-22C, ADS [automatic depressurization system] Logic System Functional Test, on May 22, 2014 ISP-66-4A, Scram Discharge Instrument Volume Water Level Transmitter Calibration**, on May 28, 2014 ISP-71B, Intermediate Range Monitor Division B Instrument Trip Functional Calibration, on June 2, 2014 ISP-103B, PCIS [primary containment isolation system] Group 1 Isolation Reactor Level Instrument Response Time Test (ATTS)[analog transmitter trip system]**, on June 9, 2014 SP-01.02, Reactor Water Sampling and Analysis, on June 11, 2014 ST-24J, RCIC [reactor core isolation cooling] Flow Rate and Inservice Test (IST), on June 16, 2014
b. Findings
No findings were identified.
RADIATION SAFETY
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed and assessed Entergy staffs performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR 20 and guidance in Regulatory Guide (RG) 8.38 Control of Access to High and Very High Radiation Areas for Nuclear Plants, TSs, and Entergys procedures required by TSs as criteria for determining compliance.
Radiological Hazard Assessment The inspectors reviewed the last two radiological surveys from the reactor building 328 elevation, the reactor building southeast quadrant, and the reactor building traversing in-core probe room. The inspectors evaluated whether the 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.
Instructions to Workers The inspectors selected five containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with 10 CFR 20 requirements. The inspectors reviewed two occurrences where a workers electronic personal dosimeter (EPD) alarmed. The inspectors evaluated whether workers responded appropriately. The inspectors assessed whether the issue was included in the CAP and whether compensatory dose evaluations were conducted. For work activities that could suddenly increase radiological conditions, the inspectors assessed Entergys means to inform workers of these changes.
Contamination and Radioactive Material Control The inspectors selected three sealed sources from the Entergy 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 with 10 CFR 20 requirements.
Radiological Hazards Control and Work Coverage The inspectors evaluated radiological conditions and performed independent radiation measurements during walkdowns of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits (RWPs), and associated worker briefings.
The inspectors evaluated the adequacy of radiological controls, surveys, radiation protection job coverage, and contamination controls. The inspectors evaluated Entergy staffs use of EPDs in high noise areas. The inspectors assessed whether radiation monitoring devices were placed on the individuals body consistent with Entergys procedures. The inspectors examined Entergys physical and programmatic controls for highly activated and contaminated materials stored within the SFP. 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 high radiation areas (HRAs) and locked high radiation areas to verify conformance with the occupational performance indicator.
Risk-Significant HRA and Very High Radiation Area (VHRA) Controls The inspectors discussed with the Radiation Protection Manager the controls and procedures for HRAs and VHRAs. The inspectors assessed whether any changes to Entergys relevant procedures reduced the effectiveness and level of worker protection. The inspectors discussed with first-line health physics supervisors the controls in place for areas that have the potential to become VHRAs 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.
The inspectors evaluated Entergys controls for VHRAs and areas with the potential to become a VHRA to ensure that an individual was not able to gain unauthorized access to these VHRAs.
Radiation Protection Technician Proficiency The inspectors observed the performance of the radiation protection 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.
The inspectors reviewed two radiological CRs since the last inspection that attributed the cause of the event to radiation protection technician error. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by Entergy staff to resolve the reported problems.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors verified in-plant airborne concentrations were being controlled consistent with as low as is reasonably achievable (ALARA) principles and the appropriate use of respiratory protection devices. The inspectors used the requirements in 10 CFR 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TSs, and Entergy procedures required by TSs as criteria for determining compliance.
Inspection Planning The inspectors reviewed the FitzPatrick 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. The inspectors reviewed the respiratory protection program and the types of protective devices used. The inspectors reviewed the UFSAR, TSs, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus (SCBA), as well as procedures for air quality maintenance.
The inspectors reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.
Use of Respiratory Protection Devices The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration.
The inspectors reviewed records of air testing for supplied-air devices and SCBA bottles to assess whether the air used in these devices met or exceeded Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they met the minimum pressure and airflow requirements for the devices in use.
The inspectors selected three individuals qualified to use respiratory protection devices and assessed whether they were deemed qualified to use the devices by successfully passing an annual medical examination, respirator fit-test, and relevant respiratory protection training.
The inspectors selected three individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device.
Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence (loss of power, loss of air, etc.).
The inspectors chose five respiratory protection devices staged and ready for use in the plant. The inspectors assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspectors selected several of the devices and reviewed records of maintenance on the vital components.
SCBA for Emergency Use The inspectors reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspectors reviewed Entergys capability for refilling and transporting SCBA air bottles to and from the control room and the operations support center during emergency conditions. The inspectors selected three individuals on control room shift crews and from designated departments currently assigned emergency duties to assess whether control room operators and other emergency response and radiation protection personnel were trained and qualified in the use of SCBA. The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task.
The inspectors determined whether appropriate mask sizes and types were available for use. The inspectors determined whether on-shift operators had any facial hair that would interfere with the sealing of the mask to the face and whether vision correction mask inserts were available, as appropriate.
The inspectors reviewed the past two years of maintenance records for three SCBA units to assess whether any maintenance and repairs were performed by individuals certified by the manufacturer of the device to perform the work. For those SCBAs that were ready for use, the inspectors verified that the required periodic air cylinder hydrostatic testing was documented and up to date.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors verified that occupational dose was appropriately monitored, assessed, and reported by Entergy. The inspectors used the requirements in 10 CFR 20, the guidance in RG 8.13, Instructions Concerning Prenatal Radiation Exposures, RG 8.36, Radiation Dose to Embryo Fetus, RG 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and Entergys procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the results of Entergys radiation protection program audits related to internal and external dosimetry. The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) report on the principal dosimetry used to establish dose of legal record. A review was conducted of Entergys procedures associated with dosimetry operations, including issuance/use of external dosimetry, and assessments of external and internal dose for radiological incidents. The inspectors evaluated whether Entergy staff had established procedural requirements for determining when external dosimetry and internal dose assessments are required.
External Dosimetry The inspectors evaluated whether Entergys dosimetry vendor was NVLAP accredited and if the approved irradiation test categories for each type of personnel dosimeter used were consistent with the radiation present and the appropriate use of the dosimeter. The inspectors evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading.
The inspectors assessed the use of EPDs to determine if Entergy used a correction factor to address the response of the EPD as compared to the dosimeter of legal record for situations when the EPD was used to assign dose. The inspectors reviewed three dosimetry CAP documents for adverse trends related to EPDs. The inspectors assessed whether Entergy staff had identified any adverse trends and implemented appropriate corrective actions.
Internal Dosimetry - Routine Bioassay (In Vivo)
The inspectors reviewed procedures used to assess the dose from internally deposited radionuclides using whole body count (WBC) equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, determining the route of intake, and the assignment of dose. The inspectors reviewed the whole body count process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides.
Special Bioassay (In Vitro)
The inspectors selected one internal dose assessment obtained using WBCs.
Internal Dose Assessment - WBC Analyses The inspectors reviewed one dose assessment performed by Entergy staff using the results of WBC analyses. The inspectors determined whether affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with Entergy's procedures.
Special Dosimetric Situations - Declared Pregnant Workers The inspectors assessed whether Entergy staff informed workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy. The inspectors reviewed the records for two individuals who had declared pregnancy during the current assessment period and evaluated whether Entergys radiological monitoring program (internal and external) for declared pregnant workers was technically adequate to assess the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls that were implemented.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
The inspectors verified that Entergy staff assured the accuracy and operability of radiation monitoring instruments that are used to protect occupational workers and to protect the public from nuclear power plant operations. The inspectors used the requirements in 10 CFR 20, 10 CFR 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases, 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations, NUREG 0737, Clarification of Three Mile Island Corrective Action Requirements, TSs/Offsite Dose Calculation Manual (ODCM), applicable industry standards, and Entergys procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed Fitzpatricks UFSAR to identify radiation instruments associated with monitoring area radiation, airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspectors reviewed the associated TS requirements for post-accident monitoring instrumentation. The inspectors reviewed Entergys and third-party evaluation reports of the radiation monitoring program since the last inspection including evaluations of offsite calibration facilities and services. The inspectors reviewed effluent monitor alarm set-point bases and the calculation methods provided in the ODCM.
Walkdowns and Observations The inspectors walked down five effluent radiation monitoring systems, including one liquid and one gaseous effluent system. The inspectors compared the effluent/process monitor configuration with what was described in the UFSAR and ODCM.
Process and Effluent Monitors The inspectors selected three effluent monitor instruments and evaluated whether channel calibration and functional tests were performed consistent with Fitzptricks TSs/ODCM.
The inspectors assessed whether Entergy calibrated its monitors with National Institute of Standards and Technology traceable sources, primary calibrations adequately represent the plant radionuclides, secondary calibration sources were verified by comparison with the primary calibration source, and Entergys channel calibrations encompassed the instruments alarm set-point range.
The inspectors assessed whether the effluent monitor alarm set-points were established in accordance with Fitzpatricks ODCM and station procedures.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
The inspectors verified that gaseous and liquid effluent processing systems were maintained so radiological discharges were properly reduced, monitored, and released.
The inspectors also verified the accuracy of the calculations for effluent releases and public doses.
The inspectors used the requirements in 10 CFR 20, 10 CFR 50.35(a), TS, 10 CFR 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases, 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water- Cooled Nuclear Power Reactor Effluents, 10 CFR 50.75(g), Reporting and Recordkeeping for Decommissioning Planning, 40 CFR 141, Maximum Contaminant Levels for Radionuclides, 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations, RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents, RG 1.21, Measuring, Evaluating, Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste, RG 4.1, Radiological Environmental Monitoring for Nuclear Power Plants, RG 4.15, Quality Assurance for Radiological Monitoring Programs, NUREG 1302, Offsite Dose Calculation Manual (ODCM) Guidance: Standard Radiological Effluent Controls, applicable Industry standards, and Entergy procedures required by TSs/ODCM as criteria for determining compliance.
Event Report and Effluent Report Reviews The inspectors reviewed the Fitzpatrick Radioactive Effluent Release Reports for 2012 and 2013. The inspectors reviewed anomalous results, unexpected trends, abnormal releases, and radioactive effluent monitor operability issues that were identified. The inspectors determined if these effluent issues were evaluated, were entered in the CAP, and were adequately resolved.
ODCM and UFSAR Review The inspectors reviewed the Fitzpatrick UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths to identify system design features and required functions.
The inspectors reviewed changes to Fitzpatricks ODCM made by Entergy since the last inspection.
The inspectors reviewed Entergy documentation for any non-radioactive systems that have become contaminated based on a review of event reports and the ODCM. The inspectors reviewed selected 10 CFR 50.59 evaluations to screen for any newly contaminated systems that had an unmonitored effluent discharge path to the environment.
Groundwater Protection Initiative (GPI) Program The inspectors reviewed reported groundwater monitoring results and changes to Entergys written program for identifying and controlling contaminated spills/leaks to groundwater.
Procedures, Special Reports, and Other Documents The inspectors reviewed Licensee Event Reports and other reports related to the effluent program issued since the previous inspection. The inspectors reviewed effluent program implementing procedures, including those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations. The inspectors reviewed copies of Entergy and third party (independent) evaluation reports of the effluent monitoring program since the last inspection of this program.
Walkdowns and Observations The inspectors walked down selected components of the gaseous and liquid discharge systems to verify that equipment configuration and flow paths align with the descriptions in the UFSAR and to assess equipment material condition. The inspectors reviewed effluent system material condition and surveillance records for equipment that was not readily accessible due to radiological conditions. The inspectors walked down filtered ventilation systems to verify there were no degraded conditions associated with high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the system. The inspectors observed the routine processing and discharge of radioactive gaseous effluent to verify that appropriate treatment equipment was used and the processing activities align with discharge permits. The inspectors determined that Entergy had not made any changes to their effluent release paths since the previous inspection of this program area. The inspectors observed the routine processing and discharge of liquid waste. The inspectors verified that appropriate effluent treatment equipment was being used and that radioactive liquid waste was being processed and discharged in accordance with procedures.
Sampling and Analyses The inspectors selected three effluent sampling activities, and assessed whether adequate controls were implemented to ensure representative samples were obtained.
The inspectors determined that there were no effluent discharges made with inoperable effluent radiation monitors. The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection of this program area. The inspectors reviewed the results of the inter-laboratory and intra-laboratory comparison program to verify the quality of the radioactive effluent sample analyses. The inspectors also assessed whether the intra-laboratory and inter-laboratory comparison program included hard-to-detect isotopes.
Effluent Flow Measuring Instruments The inspectors reviewed the methodology that Entergy used to determine the effluent stack and vent flow rates to verify that the flow rates were consistent with TSs, ODCM, and UFSAR values. The inspectors reviewed the differences between assumed and actual stack and vent flow rates.
Air Cleaning Systems The inspectors assessed whether surveillance test results for TS-required ventilation effluent discharge systems met the acceptance criteria.
Dose Calculations The inspectors reviewed changes in currently reported public dose calculation results compared to the previous radioactive effluent release report. The inspectors reviewed two radioactive liquid permits and one gaseous waste discharge permit to verify that the projected doses to members of the public were accurate. The inspectors evaluated the methods used to ensure that all potential radionuclides in the effluent stream were included in the effluent reports. The review included comparison with the current waste stream analysis results to ensure any hard-to-detect radionuclides were included in the effluent releases.
The inspectors reviewed changes in Entergys methodology for offsite dose calculations since the last inspection to verify the changes were consistent with the ODCM and RG 1.109. The inspectors verified that meteorological dispersion and deposition factors used in the effluent dose calculations were accurate. The inspectors reviewed the latest Land Use Census to verify changes that affect public dose pathways had been factored into the dose calculations and environmental sampling/analysis program. The inspectors evaluated whether the calculated doses were within the 10 CFR 50, Appendix I and TS dose criteria. The inspectors determined that there were no records of any abnormal gaseous or liquid tank discharges.
GPI Implementation The inspectors reviewed monitoring results of the voluntary Nuclear Energy Institute (NEI)
GPI to determine if Entergy has implemented the GPI as required. For anomalous results or missed samples, the inspectors assessed whether Entergy had identified and addressed deficiencies through its CAP. The inspectors reviewed recently identified leakage or spill events and entries made into Entergys decommissioning files. The inspectors reviewed evaluations of leaks or spills, determined whether Entergy staff completed offsite notifications, and reviewed the effectiveness of associated remediation actions.
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
a. Inspection Scope
The inspectors verified the effectiveness of Entergys programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR 20, 61, and 71, 10 CFR 50, Appendix A, Criterion 63, Monitoring Fuel and Waste Storage, and Entergy procedures required by the TSs/Process Control Program (PCP) as criteria for determining compliance.
Inspection Planning The inspectors reviewed the solid radioactive waste system description in the UFSAR, the PCP, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed. The inspectors reviewed the scope, the results, and the adequacy of Entergys corrective actions of quality assurance (QA) audits performed for this area since the last inspection.
Radioactive Material Storage The inspectors inspected areas where containers of radioactive waste were stored. The inspectors verified that the radioactive materials storage areas were controlled and posted as appropriate. The inspectors verified that Entergy staff had established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water). The inspectors verified that radioactive waste containers showed no signs of swelling, leakage, or deformation.
Radioactive Waste System Walkdown The inspectors walked down accessible portions of liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions in the UFSAR, ODCM, and PCP. The inspectors identified radioactive waste processing equipment that was not operational and/or was abandoned in place, and verified that Entergy staff had established administrative and/or physical controls for the protection of personnel from unnecessary exposure. The inspectors confirmed that no significant changes had been made to the radioactive waste processing systems since the last inspection.
The inspectors identified processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provided representative samples of the waste product for the purposes of waste classification. The inspectors verified that Entergys PCP correctly described the current methods and procedures for dewatering waste.
Waste Characterization and Classification The inspectors identified radioactive waste streams and verified that Entergys radiochemical sample analysis results were sufficient to support radioactive waste characterization. The inspectors verified that Entergy staffs use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current analyses.
The inspectors verified that changes to plant operational parameters were taken into account to maintain the validity of the waste stream composition data between the annual or biennial sample analysis update, and verified that waste shipments continued to meet applicable requirements. The inspectors verified that Entergy had established and maintained an adequate QA program to ensure compliance with applicable waste classification and characterization requirements.
Shipment Preparation The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifests, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors verified that the requirements of any applicable transport cask certificate of compliance had been met. The inspectors verified that the receiving licensee was authorized to receive the shipment packages.
The inspectors determined that the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport. The inspectors verified that Entergys training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.
Shipping Records The inspectors identified non-excepted package shipment records and verified that the shipping documents indicated the proper shipper name, emergency response information and a 24-hour contact telephone number, accurate curie content and volume of material, and appropriate waste classification, transport index, and international shipping identification number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.
b. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 71.5, Transportation of Licensed Material, and 49 CFR 172, Subpart I, Safety and Security Plans. Specifically, Entergy personnel shipped a radioactive quantity of category 2 RAM-QC on the public highways to a waste processor without adhering to its transportation security plan. Prior to shipment, Entergy staff failed to recognize that the quantity of radioactive material met the definition of RAM-QC.
Description.
Entergy staff prepared a liner for shipment to a waste processor. The liner, containing spent mechanical filters, had a total activity of 103 curies (including 20 curies of cobalt (Co)-60) as indicated on the Uniform Low-Level Radioactive Waste Manifest (NRC Form 541), which Entergy had generated. Prior to shipment, Entergy staff failed to recognize that this shipment met the definition of a category 2 RAM-QC (more than 8.1 curies of Co-60). Entergy staff had sent an Advanced Shipment Notification form to the processor which indicated that this was not a RAM-QC shipment (Item I of the form). The processor acknowledged and returned the form two days before the shipment was made, with a hand-written correction indicating that the processor recognized that this was a RAM-QC shipment. However, Entergy staff failed to notice the hand-written note on the Notification. As a result, the shipment was made on August 22, 2013 (Shipment ID [[::JAF-2013-1500|JAF-2013-1500]]) without Entergy having implemented its transportation security plan. As corrective action, Entergy staff entered this issue into their CAP as CR-JAF-2014-02337.
Analysis.
The failure to ship material as RAM-QC was a performance deficiency that was reasonably within Entergys ability to foresee and correct, and should have been prevented. The issue was more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety cornerstone and affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. In accordance with IMC 0609, Appendix D, "Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because Entergy had an issue involving transportation of radioactive material, but it did not involve:
- (1) a radiation limit exceeded;
- (2) a breach of package during transport;
- (3) a certificate of compliance issue;
- (4) a low level burial ground nonconformance; or
- (5) a failure to make notifications or provide emergency information. This finding had a cross-cutting aspect in the area of Human Performance, Work Processes, in that the documentation (procedures)to support this activity was inadequate [H.7]. Specifically, the requirements for the transportation of RAM-QC were implemented in 2003, Entergy-FitzPatrick had not revised their shipping procedures to incorporate this regulatory change. As of the August 2013 shipment, no guidance to the shipper was incorporated into any procedures for the identification of RAMQC.
Enforcement.
10 CFR 71.5, Transportation of Licensed Material, states, in part, each licensee who transports licensed material outside the site of usage shall comply with the applicable requirements of the DOT regulations in 49 CFR parts 171 through 180.
49 CFR 172, Subpart I [49 CFR 172.800(b)] requires that known radionuclides in forms listed as RAM-QC by the NRC must adhere to a transportation security plan. Contrary to the above, Entergy made a RAM-QC shipment on August 22, 2013 (Shipment ID [[::JAF-2013-1500|JAF-2013-1500]]) without implementing the required transportation security plan. Because this violation was of very low safety significance (Green) and Entergy entered this issue into their CAP as CR-JAF-2014-02337, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (05000333/2014003-01, Failure to Properly Ship RAM-QC)
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate (2 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittals for the RCS specific activity and RCS leak rate performance indicators for the period of April 1, 2013, through March 31, 2014. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator.
Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate (first quarter 2014), and chemistry personnel taking and analyzing an RCS sample.
b. Findings
No findings were identified.
.2 Radiological Effluent TS/ODCM Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
The inspectors reviewed Entergy submittals for the radiological effluent TS/ODCM radiological effluent occurrences performance indicator for the period from the first quarter 2013 through the fourth quarter 2013. The inspectors used performance indicator definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine if the performance indicator data was reported properly during this period.
The inspectors reviewed Entergys corrective action report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated offsite dose calculations for the selected period to determine if indicator results were accurately reported. The inspectors also reviewed Entergys methods for quantifying gaseous and liquid effluents and determining effluent dose.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.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 Entergy 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 CAP and periodically attended CR screening meetings.
The inspectors evaluated whether problems associated with radiation monitoring, exposure control, the control and mitigation of in-plant airborne radioactivity, radiation monitoring instrumentation, the effluent monitoring and control program, and radioactive waste processing, handling, storage, and transportation were being identified by Entergy at an appropriate threshold and were properly addressed for resolution in Entergys CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems. The inspectors also assessed Entergys process for applying operating experience in the area of radiological protection.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
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 Entergy outside of the CAP, such as trend reports, performance indicators, system health reports, and CAP backlogs. The inspectors also reviewed Entergys CAP database for the first and second quarters of 2014 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Entergys Aggregate Performance Review Meeting Reports for the fourth quarter of 2013 and first quarter of 2014, conducted under EN-LI-121, Trending and Performance Review Process, to verify that Entergy 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 Aggregate Performance Review. 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 CAP.
However, the inspectors noted several instances where issue trending was not utilized and may have been useful. For example, there were at least 22 CRs documenting instances of emergency preparedness equipment issues during the past six months. The inspectors noted that EN-LI-121 was revised in the fourth quarter of 2013 and that the Quarterly Trend Report had been replaced by the Aggregate Performance Review Meeting Report. Although emergency preparedness communications equipment issues had been addressed in the third quarter 2013 quarterly trend report as an emerging trend, it was no longer included in the fourth quarter Aggregate Performance Review Meeting Report. Additionally, the inspectors noted that about six percent of CRs generated in the first six months of the year were for security equipment related issues, and that performance in this area had been relatively constant for the past several years.
However, it is not included in the fourth quarter Aggregate Performance Review Meeting Report. The inspectors considered that these two examples represented missed opportunities to effectively use all of the tools available in the CAP.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
Plant Events
a. Inspection Scope
On June 1, 2014, operators reduced power to 50 percent to address main condenser tube leakage. When they isolated the affected water box and commenced draining the lake water side to support repairs, operators observed a reduction in main condenser vacuum to the point that continued turbine operation was challenged. This was because as the water box drained below the level of the tube leakage, the leak became an air leak into the steam side of the condenser. On this occurrence, the leak was sufficiently large that it overwhelmed the normal condenser air removal systems, which resulted in the inability to maintain adequate condenser vacuum. In response to this condition, operators refilled the affected water box to eliminate the air in-leakage while they performed a normal plant and reactor shutdown. With the reactor shut down and the main turbine removed from service, operators were able to place the mechanical air removal pump in service and maintain adequate condenser vacuum while the affected water box was drained. During the shutdown period, operators maintained the plant in hot shutdown to facilitate the subsequent startup.
The inspectors reviewed and observed plant parameters and personnel performance during the period of shutdown operation and subsequent plant startup. The inspectors reviewed Entergy staffs follow-up actions related to the event and equipment issues identified during the shutdown to assure that Entergy implemented appropriate corrective actions commensurate with their safety significance.
b. Findings
No findings were identified.
4OA5 Other Activities
Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders (92702)
a. Inspection Scope
On August 24, 2011, the NRC issued a Confirmatory Order (EA-11-096) to Entergy Operations Inc., and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy).
The Confirmatory Order actions were agreed upon by Entergy and the NRC during an alternative dispute resolution session held on July 18, 2011, to resolve NRC concerns regarding an apparent violation of employee protection requirements at the River Bend Station. The actions focused on reorganizing the Quality Control reporting relationships, ensuring adequate training of 10 CFR 50.7, Employee Protection, and performing an effectiveness review of the Employee Concerns Program (ECP) procedures at all Entergy facilities.
By letter dated August 23, 2012, Entergy notified the NRC of the actions that had been taken in response to the requirements imposed by the Confirmatory Order. Accordingly, during the week of April 29, 2013, NRC staff from the Office of Enforcement and Region IV performed an inspection at the River Bend Station to assess the specific actions identified in Entergys response letter. NRC staff also verified implementation of the remaining actions required to satisfy the conditions set forth in the Confirmatory Order for all Entergy sites. Subsequent to this inspection, NRC staff continued to interact with Entergy regarding the adequacy of the corrective and preventive actions related to the underlying discriminatory issue.
b. Findings and Observations
No findings were identified.
During the follow-up inspection, the NRC staff reviewed Entergys ECP supervisory training and general employee training documents, the relevant lessons learned from the facts of this matter, and the fleet-wide written communication reinforcing Entergys commitment to maintaining a safety conscious work environment.
The NRC staff also reviewed the General Employee Training and Supervisory Training modules. Based on these reviews, it was determined that these training modules adequately addressed employee protection and included insights from the underlying discriminatory matter. The NRC staff determined that the supervisory training module appeared complete and included case studies as well as the specific elements from the underlying 10 CFR 50.7 Employee Protection, violation.
Additionally, NRC staff evaluated the results of Entergys effectiveness review of ECP enhancements and the associated training that arose from the corrective actions taken to address this matter. Based on the results of this evaluation it was determined that Entergy had performed the requisite reviews at each station including: examination of selected ECP Case Files, Records Retention, Concerned Individual Follow-Up, and ECP Coordinator Training. Within the areas examined, no findings were identified and in general it was determined that Entergy had adequately performed the effectiveness review of ECP procedural enhancements and the ECP training related to this matter.
During the follow-up review of the Quality Control/QA reporting relationship, it was determined that Entergys response did not ensure that persons performing the quality assurance function of receipt inspection reported to a management level sufficient to maintain organizational freedom and independence from cost and schedule were maintained. Subsequent to the identification of this performance issue, which affected the implementation of the QA program at all nine Entergy sites, the condition was entered into Entergys CAP as CR-HQN-2013-00466.
Following the identification of this issue, additional discussions were held between NRC and Entergy to clarify the intent of the settlement agreement and subsequent Confirmatory Order stemming from the earlier alternate dispute resolution mediation. As a result of these discussions, Entergys Corporate Licensing organization developed a fleet reconciliation plan to modify Entergys Quality Assurance Program Manual to require that individuals performing inspections in accordance with Quality Assurance Program Manual, Section B.12, Inspection, functionally report to the associated manager responsible for QA. As described in the corrective actions associated with CR-HQN-2013-00466, the affected individuals were those requiring certification in accordance with Quality Assurance Program Manual, Table 1, Regulatory Commitments, Section G, Regulatory Guide 1.58, Revision 1, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel, dated September 1980. In addition to revising the applicable provisions in the Quality Assurance Program Manual, corrective actions were initiated to revise implementing procedures to reflect the change in reporting relationship during the performance of required inspections as well as providing training to the affected individuals. The NRC staff confirmed that the remaining conditions of the Confirmatory Order were adequately addressed.
Based on the above reviews, the NRC determined that Entergy properly implemented the conditions specified in the Confirmatory Order and the associated actions were adequately implemented.
4OA6 Meetings, Including Exit
On July 17, 2014, the inspectors presented the inspection results to Mr. Lawrence Coyle, 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.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- C. Adner, Manager, Licensing
- R. Brown, Manager, Radiation Protection
- L. Coyle, Site Vice President
- B. Finn, Director, Nuclear Safety Assurance
- B. Ford, Senior Manager, Nuclear Safety and Licensing
- K. Irving, Manager, Systems and Components Engineering
- S. McAllister, Director, Engineering
- D. Poulin, Manager, Operations
- T. Redfearn, Manager, Security
- M. Reno, Manager, Maintenance
- B. Sullivan, General Manager, Plant Operations
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Open/Closed
- 05000333/2014003-01 NCV Failure to Properly Ship RAM-QC (Section 2RS8)