IR 05000333/2016003
| ML16315A342 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/10/2016 |
| From: | Arthur Burritt NRC/RGN-I/DRP/PB5 |
| To: | Brian Sullivan Entergy Nuclear Northeast |
| Burritt A | |
| References | |
| IR 2016003 | |
| Download: ML16315A342 (33) | |
Text
ber 10, 2016
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2016003
Dear Mr. Sullivan:
On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). On October 20, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding did not involve a violation of NRC requirements.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-333 License No. DPR-59
Enclosure:
Inspection Report 05000333/2016003 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-333 License No. DPR-59 Report No. 05000333/2016003 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, NY Dates: July 1, 2016, through September 30, 2016 Inspectors: E. Miller, Senior Resident Inspector B. Sienel, Resident Inspector S. Barr, Senior Emergency Preparedness Inspector R. Rolph, Health Physicist Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000333/2016003; 07/01/2016 - 09/30/2016; James A. FitzPatrick Nuclear
Power Plant (FitzPatrick); Follow-Up of Events and Notices of Enforcement Discretion.
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). 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, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated August 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
Cornerstone: Initiating Events
- Green.
A self-revealing Green finding (FIN) was identified for Entergy staffs failure to properly implement the requirements of EN-DC-324, Preventive Maintenance Program,
Revision 16, to ensure proper preventive maintenance (PM) was implemented for non-safety-related 4KV transformer 71T-5. Specifically, Action Request (AR) 127566, PM change request to perform inspection, cleaning, and electrical testing of 4KV transformer 71T-5 was retired without a review by engineering as required by the PM program. As a result, transformer 71T-5 remained in service beyond its effective life without proper condition monitoring and maintenance, leading to its failure and a reactor scram on June 24, 2016.
Entergy staff developed corrective actions to address the failure which included replacement of the transformer and re-establishing the condition monitoring and PM task. Entergy also performed an extent of condition review that confirmed the PM to clean, inspect, and test similar non-safety-related dry-type transformers was still active and performed within its required frequency.
This finding is more than minor because it is associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Entergy staff failed to ensure an adequate PM was in place for transformer 71T-5. The PM to ensure adequate cleaning and testing was cancelled in 2011, and transformer 71T-5 ultimately failed on June 24, 2016, resulting in a manual reactor scram. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency caused a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors did not assign a cross-cutting aspect to this finding because it is not indicative of current licensee performance. Specifically, the performance deficiency was determined to have occurred in 2011, the guidance in EN-DC-324 is clear regarding the PM change process, and no additional failures to follow the process have resulted in significant reactor transients. (Section 4OA3)
REPORT DETAILS
Summary of Plant Status
FitzPatrick began the inspection period shut down due to a forced outage associated with a reactor scram on June 24, 2016. On July 6, operators commenced a reactor startup and achieved criticality. On July 7, operators synchronized the turbine-generator to the electrical grid.
On July 8, operators achieved 84 percent power, and subsequently reduced power to 64 percent following the identification of an oil sheen on Lake Ontario. Following resolution of the oil sheen, operators restored power to 84 percent. Maximum power was limited to 84 percent due to repairs associated with a condensate booster pump. On July 28, operators reduced reactor power to 75 percent to perform condenser waterbox cleaning and a rod pattern adjustment. The unit was restored to 84 percent power on July 29. On August 19, following repairs to the condensate booster pump, operators raised reactor power to 93 percent. The reduced power of 93 percent was the maximum power achievable due to fuel depletion as FitzPatrick is at the end of this operating cycle. The maximum power will continue to decrease (coast down) until the refueling outage which is planned for the first quarter of 2017. On August 21, FitzPatrick experienced an unexpected trip of the A reactor water recirculation (RWR) pump and a 44 percent runback of the B RWR pump. Operators maintained power at 44 percent following the transient. On August 22, operators raised reactor power to 51 percent following restoration of the B RWR pump to full speed. On August 24, power was again reduced to 44 percent when operators experienced a runback of the B RWR pump during feedwater (FW) system calibration. Operators restored power to 49 percent following troubleshooting of the B RWR runback on August 25. On August 26, following repairs to the A RWR system, operators began power ascension concurrently with post-maintenance testing of the RWR system. On August 28, reactor power was restored to 91 percent and coastdown to the refueling outage continued. On September 14, 2016, FitzPatrick experienced a trip of the B FW pump, and runback of the RWR system to 54 percent. On September 21, operators restored reactor power to approximately 83 percent following repairs to the B FW pump. FitzPatrick coasted down to 80 percent power by the end of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
.1 Partial System Walkdown
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
B control room emergency ventilation air system (CREVAS) during planned A CREVAS maintenance on August 16, 2016 A residual heat removal (RHR) system during planned B RHR maintenance on August 23, 2016 A standby liquid control (SLC) system during planned B SLC maintenance on August 24, 2016 High pressure coolant injection (HPCI) system during emergent reactor core isolation cooling system maintenance on September 13, 2016 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 updated final safety analysis report (UFSAR), technical specifications (TSs), work orders (WOs), 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 identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization. Documents reviewed for each section of this report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
From August 23 - August 31, 2016, the inspectors performed a complete system walkdown of accessible portions of the HPCI system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, surveillance tests, equipment lineup check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies.
Additionally, the inspectors reviewed a sample of related CRs to ensure Entergy personnel appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterly Walkdowns
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.
Battery room 1, fire area/zone III/BR-1, on July 13, 2016 Battery room 2, fire area/zone III/BR-2, on July 13, 2016 Battery room 3, fire area/zone IV/BR-3 on July 13, 2016 Low pressure coolant injection battery room A on reactor building 344 foot elevation, fire area/zone 9/RB-1A on July 15, 2016 Low pressure coolant injection battery room B on reactor building 344 foot elevation, fire area/zone 9/RB-1A on July 15, 2016 Administration building office area and heating, ventilation, and air conditioning equipment room 300 foot elevation following a fire in the 72FN-5 exhaust fan motor, fire area/zone 1A/AD-6 on September 6, 2016
b. Findings
No findings were identified.
.2 Fire Brigade Drill
a. Inspection Scope
The inspectors observed an unannounced fire brigade drill conducted on September 22, 2016 that involved a fire in the auxiliary boiler room. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Entergy personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated the following specific attributes of the drill:
Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of portable fire extinguishers Employment of appropriate firefighting techniques Sufficient firefighting 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 brigades actions to determine whether these actions were in accordance with Entergys firefighting strategies.
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
On July 28, 2016, the inspectors observed licensed operator simulator training, which included a simulator scenario that involved the loss of the 10400 electrical bus and a loss of coolant accident, a HPCI failure to start, and RHR pump failure to start. 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
a. Inspection Scope
On July 6, 2016, the inspectors observed control room operators during a reactor startup following a forced outage. The inspectors observed crew briefs, reactivity manipulations using control rods, and synchronization of the generator to the grid. 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, and 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 Title 10 of the Code of Federal Regulations (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.
Structures Monitoring Program - turbine building on August 2, 2016 A emergency diesel generator (EDG) on August 30, 2016 Decay heat removal system on September 21, 2016
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 B residual heat removal service water pump and a planned downpower to perform condenser waterbox cleaning and a rod pattern adjustment the week of July 25, 2016 Planned B CREVAS maintenance on July 27, 2016 Planned unavailability of the A RHR pump during shutdown cooling line system flushes on August 19, 2016 Unplanned A RWR pump trip and planned B RHR and B SLC maintenance the week of August 22, 2016 B 125V station battery unavailability during the A station battery charger 71BC-1A performance test on September 7, 2016 Planned D EDG and B core spray system maintenance the week of September 19, 2016
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-2016-2802 concerning elevated bearing temperatures associated with the B residual heat removal service water pump during torus cooling on July 27, 2016 CR-JAF-2016-3012 concerning questions on instrumentation setup and therefore validity of surveillance test results for A residual heat removal service water on August 11, 2016 CR-JAF-2016-2204 regarding A RHR system loop operability based on erratic operation of minimum flow valve10MOV-16A on August 25, 2016 CR-JAF-2016-3284 concerning operability of C safety relief valve (SRV) following inspections of E and F SRVs on September 6, 2016 CR-JAF-2016-3593 concerning the failure of CREVAS Damper 70MOD-108A limit switch which prevented 70FN-4A auto start on September 19, 2016 CR-JAF-2016-3715 concerning operability of HPCI following a step change in speed and flow observed when taking the controller from automatic to manual during surveillance testing on September 26, 2016 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, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Permanent Modification - Safety Relief Valve Replacement
a. Inspection Scope
The inspectors evaluated the replacement of the 02RV-71E three-stage SRV with a two-stage SRV implemented by engineering change (EC) 64710, Replace Three-Stage SRVs 02RV-71E and 02RV-71F with Two-Stage SRVs. The E SRV serves a pressure relief function and also an automatic depressurization system (ADS) function. This EC was implemented following recent industry operating experience which identified a potential concern with the reliability of Target Rock three-stage SRVs. The E SRV was originally a two-stage valve and was modified to the three-stage design in 2010. This EC restored the valve to its original configuration.
The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. The inspectors reviewed EC 64710, the process applicability determination, the post-modification test plan, and the post-modification test results to verify that the modification did not degrade the performance capability of the ADS or pressure relief functions of the valve. The inspectors also performed a post-installation walkdown of the valve in the drywell.
b. Findings
No findings were identified.
.2 Permanent Modification - D EDG Turbocharger Pressure Switch Setpoint Change
a. Inspection Scope
The inspectors evaluated a modification to the D EDG turbocharger lube oil low pressure switch setpoint implemented by EC 62348, Lower Trip Setpoint for 93PS-1D. In November 2015, the low capacity turbocharger for the D EDG was replaced with a high capacity turbocharger which has different internal clearances. This affected the lube oil pressure following EDG shutdown, causing the lube oil low pressure switch to actuate local and control room EDG annunciators. The purpose of the pressure switch is to alarm to indicate that the turbocharger lube oil pump is not working properly. This EC was implemented to prevent the pressure switch from unnecessarily tripping and alarming the associated annunciators following normal EDG operation.
The inspectors reviewed the EC, process applicability determination, calibration procedure change, and completed calibration procedure documentation. The inspectors also observed the post-maintenance test of the EDG. The inspectors verified that the design bases, licensing bases, and performance capability of the EDG were not degraded by the modification.
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 were 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.
WO 445687 to replace outboard D main steam isolation valve full open position switch 29PNS-86D3 on July 1, 2016 WO 449453 to replace hydraulic control unit 34-07 accumulator on July 7, 2016 WO 52687875 to replace B RHR logic relay 10A-K65B on July 25, 2016 WO 428059 to replace B SLC pump 11P-2B packing on August 24, 2016
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors monitored the stations work schedule and outage risk management for the forced outage that began on June 24, 2016, and was completed on July 7, 2016. The inspectors reviewed Entergys implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the reactor startup, heatup, and synchronization to the grid and monitored controls associated with the following activities:
Configuration management, including maintenance of defense-in-depth, to maintain the key safety functions and compliance with the applicable TSs when taking equipment out of service Implementation of clearance activities and confirmation that equipment was appropriately configured to safely support the associated work or testing Configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication Status and configuration of electrical systems and switchyard activities to ensure that TSs were met Monitoring of decay heat removal operations Activities that impacted the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory additions Activities that could affect reactivity Maintenance of secondary containment as required by TSs Tracking of startup prerequisites Identification and resolution of problems related to outage activities
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-9BA, A and C EDG Full Load Test and Emergency Service Water (ESW) Pump Operability Test, on July 11, 2016 ESP-22.001, LOCA Bypass of A and C EDG Shutdown Logic Functional Test, on August 8, 2016 ST-22C, ADS Logic System Functional Test, on August 11, 2016 ISP-175A1, Reactor and Containment Cooling Instrument Functional Test/Calibration (ATTS), on August 23, 2016 ISP-32-1A, A RHR Loop Low Flow Bypass Valve Instrument Calibration, on September 9, 2016 ST-9BB, B and D EDG Full Load Test and ESW Pump Operability Test, on September 20, 2016
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System (ANS) Evaluation
a. Inspection Scope
An onsite review was conducted to assess the performance, maintenance, and testing of FitzPatricks ANS. During this inspection, the inspectors conducted a review of the ANS testing and maintenance programs. The inspectors reviewed the associated ANS procedures and the Federal Emergency Management Agency-approved ANS Design Report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted with 10 CFR 50.47(b)(5) and the related requirements of 10 CFR Part 50, Appendix E, as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 - 1 sample)
a. Inspection Scope
The inspectors conducted a review of Entergys emergency response organization (ERO)on-shift and augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of key staff to respond to an emergency event and to verify Entergys ability to activate its emergency response facilities (ERFs) in a timely manner. The inspectors reviewed Entergys emergency plan for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, the most recent drive-in drill reports, and corrective action reports related to this inspection area. The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. The inspection was conducted with 10 CFR 50.47(b)(2) and related requirements of 10 CFR Part 50, Appendix E, as reference criteria.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspectors reviewed a number of activities to evaluate the efficacy of Entergys efforts to maintain FitzPatricks emergency preparedness (EP) program. The inspectors reviewed letters of agreement with offsite agencies, the 10 CFR 50.54(q) Emergency Plan change process and practice, Entergys maintenance of equipment important to EP, records of evacuation time estimate population evaluation, and provisions for, and implementation of, primary and backup ERF maintenance. The inspectors also verified Entergys compliance at FitzPatrick with NRC EP regulations regarding emergency action levels for hostile action events, protective actions for on-site personnel during events, emergency declaration timeliness, ERO augmentation and alternate facility capability, evacuation time estimate updates, and on-shift ERO staffing analysis.
The inspectors further evaluated Entergys ability to maintain FitzPatricks EP program through their identification and correction of EP weaknesses, by reviewing a sample of drill reports, actual event reports, self-assessments, 10 CFR 50.54(t) reviews, and EP-related CRs. The inspectors reviewed a sample of EP-related CRs initiated at FitzPatrick from January 2015 through June 2016. The inspection was conducted with 10 CFR 50.47(b)and the related requirements of 10 CFR Part 50, Appendix E, as reference criteria.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
The inspectors reviewed performance in assuring the accuracy and operability of radiation monitoring instruments used to protect occupational workers during plant operations and from postulated accidents. The inspectors used the requirements in 10 CFR 20, regulatory guides, applicable industry standards, and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed Fitzpatricks UFSAR, radiation protection audits, records of in-service survey instrumentation, and procedures for instrument source checks and calibrations.
Walkdowns and Observations (1 sample)
The inspectors conducted walkdowns of plant area radiation monitors and continuous air monitors. The inspectors assessed the material condition of these instruments and that the monitor configurations aligned with the UFSAR. The inspectors checked the calibration and source check status of various portable radiation survey instruments and contamination detection monitors for personnel and equipment.
Calibration and Testing Program (1 sample)
The inspectors reviewed the current detector and electronic channel calibration, functional testing results, alarm setpoints, and the use of scaling factors for the following radiation detection instrumentation:
laboratory analytical instruments whole body counter containment high-range monitors portal monitors personnel contamination monitors small article monitors portable survey instruments area radiation monitors electronic dosimetry air samplers continuous air monitors The inspectors reviewed the calibration standards used for portable instrument calibrations and response checks to verify that instruments were calibrated by a facility that used National Institute of Science and Technology traceable sources.
Problem Identification and Resolution (1 sample)
The inspectors verified that problems associated with radiation monitoring instrumentation (including failed calibrations) were identified at an appropriate threshold and properly addressed in the CAP.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
The inspectors reviewed the treatment, monitoring, and control of radioactive gaseous and liquid effluents. The inspectors used the requirements in 10 CFR 20; 10 CFR 50, Appendix I; TSs; Offsite Dose Calculation Manual; applicable industry standards; and procedures required by TSs as criteria for determining compliance.
Walkdowns and Observations (1 sample)
The inspectors walked down the gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design. The inspectors also observed potential unmonitored release points and reviewed radiation monitoring system surveillance records and the routine processing and discharge of gaseous and liquid radioactive wastes.
Calibration and Testing Program (1 sample)
The inspectors reviewed gaseous and liquid effluent monitor instrument calibration, functional test results, and alarm setpoints based on National Institute of Standards and Technology calibration traceability and Offsite Dose Calculation Manual specifications.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Unplanned Scrams and Unplanned Scrams with Complications (2 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittals for the following Initiating Events cornerstone performance indicators (PIs) for the period of July 1, 2015, through June 30, 2016:
Unplanned Scrams Unplanned Scrams with Complications To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed Entergys operator narrative logs, event reports, 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
The inspectors reviewed Entergys submittals for the occupational radiological occurrences PI for the first quarter of 2015 through the fourth quarter of 2015. The inspectors used PI definitions and guidance contained in NEI 99-02, Revision 7, to determine the accuracy of the PI data reported. The inspectors 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 conducted walkdowns of various 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.
.3 EP Drill and Exercise Performance, ERO Drill Participation, and ANS Reliability
(3 samples)
a. Inspection Scope
The inspectors reviewed data for the following EP PIs:
Drill and exercise performance ERO drill participation ANS reliability The inspectors reviewed supporting documentation from EP drills and equipment tests from the fourth calendar quarter of 2015, when the last NRC EP inspection at FitzPatrick was conducted, through the second calendar quarter of 2016 to verify the accuracy of the reported PI data. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7, was used as reference criteria.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
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.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities.
As applicable, the inspectors verified that Entergy made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Entergys follow-up actions related to the events to assure that Entergy implemented appropriate corrective actions commensurate with their safety significance.
Unplanned downpower due to a trip of the A RWR pump and a 44 percent runback of the B RWR pump on August 21, 2016 Trip of B FW pump on September 14, 2016
b. Findings
No findings were identified.
.2 (Closed) Licensee Event Report (LER) 05000333/2016-004-00: Transformer Fault
Results in Manual Scram and Secondary Containment Vacuum Below Technical
Specification Limit (1 sample)
a. Inspection Scope
On June 24, 2016, FitzPatrick experienced an electrical fault on 71T-5, a non-safety-related electrical transformer used to supply power from 4160V to 600V electrical buses.
The fault resulted in a trip of additional electrical loads, including two reactor building closed loop cooling (RBCLC) pumps. This resulted in a loss of sufficient cooling to the reactor recirculation pump motor-generator fluid drive oil and a manual reactor scram.
Entergy entered this issue into their CAP as CR-JAF-2016-2245 and performed a root cause evaluation. The cause evaluation identified that the PM activity that existed for the transformer was cancelled in 2011. PM had not been performed since 2002, leading to a failure to perform routine cleaning and testing. When combined with two separate overloading events early in the life of the transformer, the PM would have allowed the early detection that the transformer was at the end of its effective life and susceptible to failure. Entergy staff developed corrective actions to address the failure which included replacement of the transformer and re-establishing the PM task. Entergy also performed an extent of condition review that confirmed the PM to clean, inspect, and test similar non-safety-related dry-type transformers was still active and performed within its required frequency. The inspectors reviewed this LER and the associated root cause evaluation for accuracy, the adequacy of proposed and completed corrective actions, and the appropriateness of the extent-of-condition review. This LER is closed.
b. Findings
Introduction.
A self-revealing Green FIN was identified for Entergy staffs failure to properly implement the requirements of EN-DC-324, Preventive Maintenance Program, Revision 16, to ensure proper PM was implemented for non-safety-related 4KV transformer 71T-5. Specifically, AR 127566, PM change request to perform inspection, cleaning, and electrical testing of 4KV transformer 71T-5, was retired without a review by engineering as required by the PM program. As a result, transformer 71T-5 remained in service without proper maintenance and testing, leading to its failure and a reactor scram on June 24, 2016.
Description.
Transformer 71T-5 is the unit substation for the non-safety-related 600 volts alternating current (VAC) bus 71L-13. The transformer is a dry-type, natural convection cooled step-down transformer converting 4160 VAC to 600 VAC. On June 24, 2016, a failure of 71T-5 resulted in a loss of power to 600 VAC bus 71L-13. The loss of power resulted in a trip of two out of three RBCLC pumps, the loss of additional non-safety-related electrical buses, and a manual reactor scram. The loss of 71L-13 also resulted in the loss of the ability to maintain secondary containment vacuum greater than or equal to minus 0.25 inches of water gauge. The standby gas treatment system was started and successfully restored reactor building differential pressure. Following identification of the electrical fault, operators cross-tied the 71L-14 600 VAC bus to the 71L-13 600 VAC bus, thus restoring power to RBCLC and various reactor building ventilation fans.
Entergy staff conducted a root cause evaluation, and found that the last PM performed on 71T-5 was conducted in 2002, to perform cleaning, inspection, and testing. The PM was on an 8-year frequency, and was not performed, when it was due in October 2010 during refueling outage 19. Contrary to EN-DC-324, Entergy staff cancelled the PM without an action request being initiated, reviewed, and approved, during the October 2010 outage.
Subsequently AR 127566 was generated in 2011 to evaluate the permanent removal of visual inspection, cleaning, and electrical testing associated with transformer 71T-5. This request was approved by the PM engineer, although 71T-5 was listed as High Critical, which by definition in EN-DC-324 is due to its potential failure being able to cause a significant impact to safe and reliable operation. Per EN-DC-324, Preventive Maintenance Program, Section 5.5.4, Engineering was to have the AR routed for review prior to approval. Contrary to the requirement, the PM change was not provided for review, leading to the improper cancellation of the PM for 71T-5. Given 71T-5 was listed as High Critical, the required review would have allowed this to be identified and ensure the PM was reinstated.
A CAP review identified the 71T-5 transformer was overloaded in 1992 and 1996.
Operation of this transformer beyond its rating is acceptable, but can reduce its effective life. Although the vendor does not provide a replacement frequency, the vendor did note that on average a dry-type transformer, similar to 71T-5, with reduced loading can last between 40 and 60 years. Entergy staff determined that had the PM not been cancelled, adequate cleaning and inspection would have prolonged the life of the transformer, and testing may have been able to detect that it was at the end of its effective life and susceptible to failure.
Entergy staff developed corrective actions to address the failure which included replacement of the transformer and re-establishing the PM task. Entergy also performed an extent of condition review that confirmed the PM to clean, inspect, and test similar non-safety-related dry-type transformers was still active and performed within its required frequency.
Analysis.
The inspectors determined that Entergy staffs failure to properly implement the requirements of EN-DC-324, Preventive Maintenance Program, to ensure an adequate PM was in place for transformer 71T-5 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Entergy staff failed to ensure an adequate PM was in place for transformer 71T-5. As a result, transformer 71T-5 ultimately failed on June 24, 2016, resulting in a manual reactor scram.
In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency caused a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
The inspectors did not assign a cross-cutting aspect to this finding because it is not indicative of current licensee performance. Specifically, the performance deficiency occurred in 2011, the guidance in EN-DC-324 is clear regarding the PM change process, and no additional failures to follow the process have resulted in significant reactor transients.
Enforcement.
This finding does not involve enforcement action because no violation of a regulatory requirement was identified. This finding is against procedure EN-DC-324, Preventive Maintenance Program, which is not required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, and the work being done was not on a safety-related system. The issue was entered into Entergys CAP as CR-JAF-2016-2245. Because this finding does not involve a violation and is of very low safety significance, it is identified as a FIN. (FIN 05000333/2016003-01, Inadequate Preventive Maintenance Results in Transformer Failure and Reactor Scram)
4OA5 Other Activities
.1 Institute of Nuclear Power Operations (INPO) Report Review
a. Inspection Scope
The inspectors reviewed the final report for the INPO plant assessment of FitzPatrick conducted in March 2016. The inspectors reviewed this report to ensure that any issues identified were consistent with NRC perspectives of Entergys performance and to determine if INPO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 20, 2016, the inspectors presented the inspection results to Mr. Brian Sullivan, Site Vice President, and other members of Entergy 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
- B. Sullivan, Site Vice President
- T. Peter, General Manager, Plant Operations
- C. Adner, Director, Regulatory and Performance Improvement
- D. Bittinger, Manager, Design and Programs Engineering
- W. Drews, Manager, Regulatory Assurance
- R. Heath, Manager, Radiation Protection
- J. Jones, Manager, Emergency Planning
- D. Poulin, Director, Engineering
- T. Redfearn, Manager, Security
- M. Reno, Manager, Training
- T. Restuccio, Manager, Operations
- J. Richardson, Manager, Systems and Components Engineering
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Open/Closed
- 05000333/2016003-01 FIN Inadequate Preventive Maintenance Results In Transformer Failure and Reactor Scram (Section 4OA3)
Closed
- 05000333/2016-004-00 LER Transformer Fault Results in Manual Scram and Secondary Containment Vacuum Below Technical Specification Limit (Section 4OA3)