IR 05000341/2009004
| ML092940205 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/20/2009 |
| From: | Jack Giessner Reactor Projects Region 3 Branch 4 |
| To: | Jennifer Davis Detroit Edison |
| References | |
| IR-09-004 | |
| Download: ML092940205 (39) | |
Text
ber 20, 2009
SUBJECT:
FERMI POWER PLANT, UNIT 2, INTEGRATED INSPECTION REPORT 05000341/2009004
Dear Mr. Davis:
On September 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Fermi Power Plant, Unit 2. The enclosed report documents the inspection results, which were discussed on October 9, 2009, with J. Plona and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to 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.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket No. 50-341 License No. NPF-43
Enclosure:
Inspection Report 05000341/2009004 w/Attachment: Supplemental Information
REGION III==
Docket No: 50-341 License No: NPF-43 Report No: 05000341/2009004 Licensee: Detroit Edison Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: July 1 through September 30, 2009 Inspectors: R. Morris, Senior Resident Inspector R. Jones, Resident Inspector T. Steadham, P.E., Resident Inspector J. Cassidy, Senior Health Physicist A. Dunlop, Senior Reactor Engineer J. Rutkowski, Senior Resident Inspector, Davis-Besse F. Tran, Reactor Engineer, Region III A. Wilson, Resident Inspector, Davis-Besse Observer(s): M. Abid, Reactor Engineer Approved by: J. Giessner, Chief Branch 4 Division of Reactor Projects Enclosure
TABLE OF CONTENTS Summary of Plant Status...........................................................................................................2 1. REACTOR SAFETY .......................................................................................................2 1R01 Adverse Weather Protection (71111.01) .............................................................2 IR04 Equipment Alignment (71111.04) ........................................................................4 1R05 Fire Protection (71111.05) ...................................................................................5 1R07 Heat Sink Performance (71111.07T) ...................................................................6 1R11 Licensed Operator Requalification Program (71111.11)......................................7 1R12 Maintenance Effectiveness (71111.12) ...............................................................7 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) ..........8 1R15 Operability Evaluations (71111.15)......................................................................9 1R18 Plant Modifications (71111.18) ..........................................................................10 1R19 Post-Maintenance Testing (71111.19)...............................................................10 1R22 Surveillance Testing (71111.22) ........................................................................11 1EP6 Drill Evaluation (71114.06) ................................................................................13 2OS1 Access Control to Radiologically Significant Areas (71121.01) .........................13 2OS2 As-Low-As-Reasonably-Achievable Planning and Controls (71121.02)............16 4OA1 Performance Indicator Verification (71151) .......................................................17 4OA2 Identification and Resolution of Problems (71152) ............................................20 4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) ...............22 4OA5 Other Activities...................................................................................................23 4OA6 Management Meetings ......................................................................................23 SUPPLEMENTAL INFORMATION ...............................................................................................1 KEY POINTS OF CONTACT ........................................................................................................1 List of Documents Reviewed ........................................................................................................2 List of Acronyms Used ................................................................................................................10 Enclosure
SUMMARY OF FINDINGS
IR 05000341/2009004, 07/01/2009 - 09/30/2009; Fermi Power Plant, Unit 2.
This report covers a 3-month period of inspection by resident inspectors. No findings of significance were identified by the inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings No findings of significance were identified.
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
Summary of Plant Status
Fermi Unit 2 started this inspection period at 100 percent power and remained there until September 15, 2009, when a reactor recirculation pump was tripped due to a loss of motor cooling water and power was lowered to 45 percent. The plant remained in single loop operations until September 16 when the recirculation pump was restarted. The plant returned to 100 percent power that afternoon and remained there until September 30 when the reactor was shutdown to repair a leak in the main generator stator water cooling system.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:
- coordination between the TSO and the plant during off-normal or emergency events;
- explanations for the events;
- estimates of when the offsite power system would be returned to a normal state; and
- notifications from the TSO to the plant when the offsite power system was returned to normal.
The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:
- actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;
- compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;
- re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and
- communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.
The inspectors also reviewed corrective action program (CAP) items to verify the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings of significance were identified
.2 Readiness for Impending Adverse Weather Condition - High Wind Conditions
a. Inspection Scope
The inspectors reviewed the licensees overall preparations/protection for the expected weather conditions on August 25, 2009, because thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility. The inspectors walked down the switchyards and reactor building refuel floor/spent fuel pool, in addition to the licensees emergency AC power systems, because their safety-related functions could be affected or required as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the licensee staffs preparations against the sites procedures and determined the staffs actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified operator actions were appropriate as specified by plant specific procedures. The inspectors also reviewed a sample of CAP items to verify the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the CAP in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the Attachment.
This inspection constituted one readiness for impending adverse weather condition sample as defined in IP 71111.01-05.
b. Findings
No findings of significance were identified.
.3 External Flooding
a. Inspection Scope
The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood in the residual heat removal (RHR) Complex.
The evaluation included a review to check for deviations from the descriptions provided in the UFSAR for features intended to mitigate the potential for flooding from external factors. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the building floor drains did not contain obvious loose items that could clog drains in the event of water intrusion, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site which would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier. The inspectors also walked down underground bunkers/manholes subject to flooding that contained multiple train or multiple function risk-significant cables. The inspectors also reviewed the abnormal operating procedure for mitigating the design basis flood to ensure it could be implemented as written.
This inspection constituted one external flooding sample as defined in IP 71111.01-05.
b. Findings
No findings of significance were identified.
IR04 Equipment Alignment (71111.04)
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- combustion turbine generator 11, unit 1;
- emergency diesel generator (EDG) 14 during EDG-11 safety system outage (SSO);
- Division 2 emergency equipment cooling water (EECW) after B heat exchanger work; and
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specifications (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify there were no obvious deficiencies. The inspectors also verified the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the
.
These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- reactor building fourth floor, standby liquid control area;
- EDG-13 engine, switchgear, fuel oil, and ventilation rooms;
- control center complex relay room;
- EDG-12 room;
- cable spreading room; and
- cable tray area, FZ 08AB.
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified fire hoses and extinguishers were in their designated locations and available for immediate use; fire detectors and sprinklers were unobstructed; transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the to this report.
These activities constituted six quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
.1 Triennial Review of Heat Sink Performance
a. Inspection Scope
The inspectors reviewed completed surveillances, vendor manual information, associated calculations, and cooler inspection results associated with the switchgear room east Division 1 (T4100B002) and the Division 2 core spray room east (T4100B020)coolers. These heat exchangers/coolers were chosen based on their risk significance in the licensees probabilistic safety analysis, their important safety-related mitigating system support functions and their relatively low margin.
For the switchgear room east Division 1 and the Division 2 core spray room east coolers, the inspectors verified the condition and operation of the heat exchangers were consistent with design assumptions in heat transfer calculations and as described in the UFSAR. This included verification that the number of plugged tubes was within pre-established limits based on capacity and heat transfer assumptions. The inspectors verified the licensee evaluated the potential for water hammer and established adequate controls and operational limits to prevent heat exchanger degradation due to excessive flow-induced vibration during operation. In addition, visual inspection records were reviewed to determine the structural integrity of the heat exchanger. The inspectors verified the licensees chemical treatment programs for corrosion control were consistent with industry standards and implemented accordingly.
The inspectors also verified the performance of the ultimate heat sinks by performing a system walkdown on portions of the residual heat removal service water (RHRSW),essential equipment service water (EESW), and EECW systems in the RHR complex and the reactor building to verify the licensees assessment on structural integrity (attribute D.6). In addition, the inspectors reviewed available licensees inspections and ultrasonic test results, and the history of through-wall pipe leakage to identify any adverse trends since the last NRC inspection. For closed cooling water systems, the inspectors reviewed operating logs and interviewed the system engineers to identify adverse make-up trends that could be indicative of excessive leakage out of the closed system. For buried or inaccessible piping, the inspectors reviewed the licensee's recently issued pipe testing, inspection, or monitoring program to verify structural integrity; however, a review of program implementation was not performed due to the program not being fully implemented at the time of the inspection. The periodic inspection program used to detect protective coating failures, corrosion, and erosion was also reviewed. For the RHRSW and EESW deep draft vertical pumps, the inspectors reviewed the operational history and the inservice test vibration results to assess for adverse trends.
In addition, the inspectors reviewed condition assessment and resolution documents (CARD s) related to the heat exchangers/coolers and heat sink performance issues to verify the licensee had an appropriate threshold for identifying issues and to evaluate the effectiveness of the corrective actions. The documents reviewed are listed in the to this report.
These inspection activities constituted two heat sink inspection samples as defined in IP 71111.07-05.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review
a. Inspection Scope
On August 25, 2009, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures.
The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- motor control centers and distribution cabinets.
The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- Division 2, RHRSW SSO and diesel fire pump failure;
- EDG-12, SSO;
- EDG-14, SSO;
- Division 1, standby gas treatment (SGT) outage;
- Number 4 low pressure stop valve lockdown;
- Division 1, EECW pump failure and single loop operations; and
- Division 1, EECW heat exchanger outage.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
These maintenance risk assessments and emergent work control activities constituted seven samples as defined in IP 71111.13-05.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issue:
- CARDs 09-26243 and 09-26310, Fermi Licensed Operator Qualification and Control Room Staffing; and
- CARD 09-24229, South Turbine Exhaust Fan High Vibration.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure TS operability was properly justified and the subject components or systems remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensees 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. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
This operability inspection constituted two samples as defined in IP 71111.15-05
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed the following temporary modifications:
- TM 03-0018, Install New Fuel Tank for Temporary Diesel Generator; and
- TM 09-0022, Provide and Alternate Means of Air Flow to the North 3, 4, and 5 Heater Rooms and the Turbine Building Steam Tunnel.
The inspectors compared the temporary configuration changes and associated 10 CFR 50.59 screening and evaluation information against the design basis, the UFSAR, and the TS, as applicable, to verify the modification did not affect the operability or availability of the affected system(s). The inspectors also compared the licensees information to operating experience information to ensure lessons learned from other utilities had been incorporated into the licensees decision to implement the temporary modification. The inspectors, as applicable, performed field verifications to ensure the modifications were installed as directed; the modifications operated as expected; modification testing adequately demonstrated continued system operability, availability, and reliability; and operation of the modifications did not impact the operability of any interfacing systems. Lastly, the inspectors discussed the temporary modification with operations, engineering, and training personnel to ensure the individuals were aware of how extended operation with the temporary modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the to this document.
This inspection constituted two temporary modification samples as defined in IP 71111.18-05.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance (PM) activities to verify procedures and test activities were adequate to ensure system operability and functional capability:
- WO 28687664, Calibrate and Inspect Division 2 SGTS Exhaust Fan Control Loop; WO 27094970, Perform General PM-SGTS Exhaust Fan;
- WO 080070100, EECW Heat Exchanger PMT Following Cleaning;
- WO 30270126, Remove and Replace No. 1 low pressure intercept valve (LPIV)
Fast Close Dump Solenoid Valves;
- WO 25998923, Perform motor operated valve (MOV) Inspection for E4150F022;
- WO 28257595, Repair Outer Airlock Door Seal;
- WO 30301191, Replace diesel fire pump (DFP) Fuel Injectors;
- WO 30284277, Change No. 4 LPSV Unloader and Relief Valves;
- WO 30349299, Replace Division 1 EECW Pump Breaker;
- WO T538100100, Replace Division 1 control center heating and ventilation (CCHVAC) SGTS Room Isolation Damper Solenoid Valve per NE-6.6EQMS.030.
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure the test results adequately ensured the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with PM tests to determine whether the licensee was identifying problems and entering them in the CAP and the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted twelve PM testing samples as defined in IP 71111.19-05.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- Procedure 24,204.02, Division 2 Low Pressure Coolant Injection and Torus Cooling Pump and Valve Testing, (IST); and
- Procedure 24.207.08, Division 1 EECW C Heat Exchanger Surveillance, (Routine).
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency were in accordance with TSs, the UFSAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one routine surveillance testing sample, and one inservice testing sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of routine licensee emergency drills on August 18 and August 25, 2009, to identify any weaknesses and deficiencies in classifications, notifications, and protective action recommendations development activities. The inspectors observed emergency response operations in the Control Room Simulator, Emergency Offsite Facility, Technical Support Center, and Operations Support Center to determine whether the event classifications, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critiques to compare any inspector-observed weaknesses with those identified by the licensee staff in order to evaluate the critiques and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of these inspections, the inspectors reviewed the drill packages and other documents listed in the Attachment to this report.
This emergency preparedness drill inspection constituted two samples as defined in IP 71114.06-05.
b. Findings
No findings of significance were identified.
2OS1 Access Control to Radiologically Significant Areas (71121.01)
.1 Plant Walkdowns and Radiation Work Permit Reviews
a. Inspection Scope
The inspectors reviewed radiation work permits for airborne radioactivity areas to verify barrier integrity and engineering controls performance (e.g. high-efficiency particulate air ventilation system operation) and to determine if there was a potential for individual worker internal exposures in excess of 50 millirem committed effective dose equivalent.
There were no airborne radioactivity work areas during the inspection period.
Work areas having a history of, or the potential for, airborne transuranics were evaluated to verify that the licensee had considered the potential for transuranic isotopes and had provided appropriate worker protection.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors assessed the adequacy of the licensees internal dose assessment process for internal exposures in excess of 50 millirem committed effective dose equivalent. There were no internal exposures greater than 50 millirem committed dose equivalent.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors also reviewed the licensees physical and programmatic controls for highly activated and/or contaminated materials (non-fuel) stored within the spent fuel pool or other storage pools.
This inspection constituted one sample as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified.
.2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed a sample of the licensees self-assessments, audits, Licensee Event Reports, and Special Reports related to the access control program to verify that identified problems were entered into the CAP for resolution.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors reviewed corrective action reports related to access controls and any high radiation area radiological incidents (issues that did not count as performance indicator (PI) occurrences identified by the licensee in high radiation areas less than 1R/hr). Staff members were interviewed and corrective action documents were reviewed to verify that follow-up activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk based on the following:
- initial problem identification, characterization, and tracking;
- disposition of operability/reportability issues;
- evaluation of safety significance/risk and priority for resolution;
- identification of repetitive problems;
- identification of contributing causes;
- identification and implementation of effective corrective actions;
- resolution of non-cited violations tracked in the corrective action system; and
- implementation/consideration of risk significant operational experience feedback.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors evaluated the licensees process for problem identification, characterization, and prioritization and verified that problems were entered into the CAP and resolved. For repetitive deficiencies and/or significant individual deficiencies in problem identification and resolution, the inspectors verified that the licensees self-assessment activities were capable of identifying and addressing these deficiencies.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors reviewed licensee documentation packages for all PI events occurring since the last inspection to determine if any of these PI events involved dose rates in excess of 25 R/hr at 30 centimeters or in excess of 500 R/hr at 1 meter. Barriers were evaluated for failure and to determine if there were any barriers left to prevent personnel access. Unintended exposures exceeding 100 millirem total effective dose equivalent (or 5 rem shallow dose equivalent or 1.5 rem lens dose equivalent) were evaluated to determine if there were any regulatory overexposures or if there was a substantial potential for an overexposure.
This inspection constituted one sample as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified.
.3 High Risk Significant, High Dose Rate, High Radiation Area and Very High Radiation
Area Controls
a. Inspection Scope
The inspectors held discussions with the Radiation Protection Manager concerning high dose rate, high radiation area and very high radiation area controls and procedures, including procedural changes that had occurred since the last inspection, in order to assess whether any procedure modifications substantially reduced the effectiveness and level of worker protection.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors discussed with radiation protection supervisors the controls that were in place for special areas of the plant that had the potential to become very high radiation areas during certain plant operations. The inspectors assessed if plant operations required communication beforehand with the radiation protection group, so as to allow corresponding timely actions to properly post and control the radiation hazards.
This inspection constituted one sample as defined in IP 71121.01-5.
The inspectors conducted plant walkdowns to assess the posting and locking of entrances to high dose rate high radiation areas and very high radiation areas.
This inspection constituted one sample as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified
.4 Radiation Worker Performance
a. Inspection Scope
The inspectors reviewed radiological problem reports for which the cause of the event was due to radiation worker errors to determine if there was an observable pattern traceable to a similar cause and to determine if this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. Problems or issues with planned or completed corrective actions were discussed with the Radiation Protection Manager. This inspection constituted one sample as defined in IP 71121.01-5.
This inspection constituted one sample as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified.
.5 Radiation Protection Technician Proficiency
a. Inspection Scope
The inspectors reviewed radiological problem reports for which the cause of the event was radiation protection technician error to determine if there was an observable pattern traceable to a similar cause and to determine if this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.
This inspection constituted one sample as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified.
2OS2 As-Low-As-Reasonably-Achievable Planning and Controls (71121.02)
.1 Radiological Work Planning
a. Inspection Scope
The inspectors compared the results achieved (including dose rate reductions and person-rem used) with the intended dose established in the licensees as-low-as-reasonably achievable (ALARA) planning for these three work activities. Reasons for inconsistencies between intended and actual work activity doses were reviewed.
- drywell recirculation motor B activities;
- RB5 disassembly, reassemble, refuel activities; and
- reactor building/auxiliary building scaffold activities.
This inspection constituted one required sample as defined in IP 71121.02-5.
The inspectors assessed the integration of ALARA requirements into work procedures and radiological work planning documents to assess whether the licensee was implementing actions in radiological job planning in order to reduce dose.
This inspection constituted one optional sample as defined in IP 71121.02-5.
The licensees post-job (work activity) reviews were evaluated to verify that identified problems were entered into the licensees CAP.
This inspection constituted one optional sample as defined in IP 71121.02-5.
b. Findings
No findings of significance were identified.
.2 Source-Term Reduction and Control
a. Inspection Scope
The inspectors verified that the licensee had developed an understanding of the plant source-term, including knowledge of input mechanisms to reduce the source-term. The inspectors evaluated if the licensee had a source-term control strategy in place that included a cobalt reduction strategy, shutdown controls, and operating chemistry plan, which was designed to minimize the source-term external to the core. Other methods used by the licensee to control the source-term, including component and system decontamination and the use of shielding, were also evaluated.
This inspection constituted one optional sample as defined in IP 71121.02-5.
The inspectors reviewed the licensees identification of specific sources of radiation, along with exposure reduction actions and the priorities the licensee had established for implementation of those actions. The results that had been achieved against these priorities since the last refueling cycle were reviewed. For the current assessment period, source reduction evaluations were verified along with actions taken to reduce the overall source-term compared to the previous year.
This inspection constituted one optional sample as defined in IP 71121.02-5.
b. Findings
No findings of significance were identified.
.3 Declared Pregnant Workers.
a. Inspection Scope
The inspectors reviewed dose records of declared pregnant workers for the current assessment period to verify that the exposure results and monitoring controls employed by the licensee complied with the requirements of 10 CFR Part 20.
This inspection constituted one required sample as defined in IP 71121.02-5.
b. Findings
No findings of significance were identified
4OA1 Performance Indicator Verification
Cornerstones: Mitigating Systems, Public Radiation Safety, and Occupational Radiation Safety
.1 Mitigating Systems Performance Index - High Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - High Pressure Injection Systems PI for the period from the third quarter 2008 through the second quarter 2009. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports for the period of the third quarter 2008 through the second quarter 2009 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one MSPI high pressure injection system sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.2 Mitigating Systems Performance Index - Heat Removal System
a. Inspection Scope
The inspectors sampled licensee submittals for the MSPI - Heat Removal System PI for the period from the third quarter 2008 through the second quarter 2009. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC Integrated Inspection Reports for the period the third quarter 2008 through the second quarter 2009 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one MSPI heat removal system sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.3 Reactor Coolant System Specific Activity
a. Inspection Scope
The inspectors sampled licensee submittals for the Reactor Coolant System (RCS)
Specific Activity performance indicator for the period from the second quarter 2008 through second quarter 2009. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees RCS chemistry samples, TS requirements, issue reports, event reports and NRC Integrated Inspection Reports for the period from the second quarter 2008 through second quarter 2009 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one reactor coolant system specific activity sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.4 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors sampled licensee submittals for the Occupational Radiological Occurrences performance indicator for the period from the second quarter 2008 through second quarter 2009. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine if indicator related data was adequately assessed and reported. To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with radiation protection staff, the scope and breadth of its data review, and the results of those reviews. The inspectors independently reviewed electronic dosimetry dose rate and accumulated dose alarm and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one occupational radiological occurrences sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.5 Radiological Effluent TS/Offsite Dose Calculation Manual Radiological Effluent
Occurrences
a. Inspection Scope
The inspectors sampled licensee submittals for the Radiological Effluent TS (RETS)/Offsite Dose Calculation Manual (ODCM) Radiological Effluent Occurrences performance indicator for the period of the second quarter 2008 through second quarter 2009. The inspectors used Performance Indicator (PI) definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5 to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees issue 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 effluent summary data and the results of associated offsite dose calculations for selected dates between the second quarter 2008 through second quarter 2009 to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one RETS/ODCM radiological effluent occurrences sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the attached List of Documents Reviewed.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings of significance were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
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 licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings of significance were identified.
.3 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds (OWAs) on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.
The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP and proposed or implemented appropriate and timely corrective actions which addressed each issue. Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed.
Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified OWAs.
This review constituted one OWA annual inspection sample as defined in IP 71152-05.
b. Findings
No findings of significance were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Unplanned Shutdown of Reactor Recirculation Pump A
a. Inspection Scope
The inspectors reviewed the plants response to an unplanned shutdown of reactor recirculation pump A. On September 15, 2009, the licensee was performing Division 1 EECW pump and valve operability surveillance, 24.207.08. During step 5.1.11 the operator performed an initiation of Division 1 of EECW. The EECW pump was suppose to start and the EECW valves reposition. The valves repositioned as expected but the EECW pump failed to start and indicated tripped. This condition required an Abnormal Operating Procedure entry for loss of Reactor Building Closed Cooling Water (RBCCW)and the operators tripped the North Reactor Recirculation pump placing the plant in single loop operations. The plant equipment responded as designed. The operators restored RBCCW and placed the plant in a stable condition. The operators restarted the recirculation pump in accordance with procedures and returned the plant to 100 percent power on September 16. Documents reviewed in this inspection are listed in the
.
This event follow-up review constituted one sample as defined in IP 71153-05.
b. Findings
No findings of significance were identified.
.2 Unplanned Reactor Shutdown Due to Hydrogen In-Leakage to Stator Water Cooling
System
a. Inspection Scope
The inspectors reviewed the plants response to an unplanned reactor shutdown due to a hydrogen leak into the stator water cooling system in the main turbine generator. On September 30, 2009, the reactor mode switch was taken to shutdown and the main turbine generator was manually tripped in response to an increase in a hydrogen gas leak into the main turbine generator stator water cooling system. The SCRAM was uncomplicated and all plant equipment responded as designed. The plant was stabilized and the operators began a cooldown to Mode 4. The inspectors reviewed the site personnel and plant response to the event to ensure all safety systems and operators responses were as expected. The inspectors also reviewed the immediate reporting requirements to ensure they were in accordance 10CFR 50.72. At the end of the inspection period the plant was in Mode 4 on RHR cooling and the licensee was cooling down the main turbine and generator to perform a search for the leak into the main turbine generator stator water cooling system.
This event follow-up review constituted one sample as defined in IP 71153-05.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 9, 2009, the inspectors presented the inspection results to J. Plona, Site VP, T. Conner, Plant Manager and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- the triennial heat sink inspection with Kevin Hlavaty, Plant Manager, and other members of the licensees staff, on July 10, 2009; and
- the Access Control to Radiologically Significant Areas program inspection with the Site Vice-President, J. Plona, and other members of the licensees staff on September 18, 2009.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- J. Plona, Site Vice-President
- T. Conner, Plant Manager
Kevin Hlavaty, Plant Manager
- M. Caragher, Director, Engineering
- E. Hare, Supervisor Components, Systems
- R. Johnson, Manager, Licensing
- R. Salmon, Principal Licensing Engineer
- J. Schulist, Director, Corporate, DTE
- G. Wojtowicz, Technical Expert, PSE
Nuclear Regulatory Commission
- J. Giessner, Branch 4
Attachment