IR 05000341/2013004

IR 05000341-13-004; on 07/01/2013 - 09/30/2013; Fermi Power Plant, Unit 2; Integrated Inspection Report

ML13295A554
Person / Time
Site:	Fermi
Issue date:	10/22/2013
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Plona J DTE Electric Company
References
IR-13-004
Download: ML13295A554 (41)

Text

UNITED STATES ber 22, 2013

SUBJECT:

FERMI POWER PLANT, UNIT 2, NRC INTEGRATED INSPECTION REPORT 05000341/2013004

Dear Mr. Plona:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Fermi Power Plant, Unit 2. The enclosed inspection report documents the inspection results which were discussed on October 2, 2013, with Mr. T. Conner and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings were identified.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket No. 50-341 License No. NPF-43

Enclosure:

Inspection Report 05000341/2013004 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-341 License No: NPF-43 Report No: 05000341/2013004 Licensee: DTE Electric Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: July 1 through September 30, 2013 Inspectors: B. Kemker, Senior Resident Inspector R. Morris, Senior Resident Inspector R. Jones, Resident Inspector K. Carrington, Acting Resident Inspector S. Bell, Health Physicist D. Jones, Reactor Inspector D. Kimble, Senior Resident Inspector, Davis-Besse Approved by: M. Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000341/2013004; 07/01/2013 - 09/30/2013; Fermi Power Plant, Unit 2;

Integrated Inspection Report.

This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No findings were identified.

REPORT DETAILS

Summary of Plant Status

Fermi Power Plant, Unit 2, operated at about 68 percent power until September 9, 2013, when the licensee shut down the unit for a planned maintenance outage to replace the south reactor feedwater pump and to complete additional plant maintenance. The licensee restarted the unit on September 22 and returned it to 100 percent power on October 2, after completing extensive testing of the rebuilt south reactor feedwater pump and fuel conditioning for the higher power level. The unit was operating at about 100 percent power at the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• Standby Liquid Control system;

• Division 1 Standby Gas Treatment system while protected for Emergency Equipment Cooling Water Safety system outage; and

• Division 2 Residual Heat Removal (RHR) system while protected for Emergency Diesel Generator (EDG) 12.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones. The inspectors reviewed operating procedures, system diagrams, Technical Specification (TS) requirements, 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 available. The inspectors observed operating parameters and examined the material condition of the equipment to verify there were no obvious deficiencies.

In addition, the inspectors verified equipment alignment problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected condition assessment resolution documents (CARDs) were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted three partial system walkdown inspection samples as defined in Inspection Procedure (IP) 71111.04.

b. Findings

No findings 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, Division 2 RHR Heat Exchanger Room;

• Auxiliary Building, Second Floor Mezzanine - Cable Tray Area;

• Torus Room;

• Circulating Water Pump House;

• Auxiliary Building, First Floor Mezzanine; and

• Auxiliary Building, Control Room Relay Room.

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. 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.

In addition, the inspectors verified fire protection related problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected CARDS were reviewed to verify corrective actions were appropriate and implemented as scheduled.

This inspection constituted six quarterly fire protection inspection samples as defined in IP 71111.05AQ.

b. Findings

No findings were identified.

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the Updated Final Safety Analysis Report (UFSAR), engineering calculations, and abnormal operating procedures to identify licensee commitments. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed corrective action program documents associated with past flooding-related items to verify identified problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected CARDS were reviewed to verify corrective actions were appropriate and implemented as scheduled.

The inspectors performed a walkdown of accessible portions of the following plant area to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were functional, and the licensee complied with its commitments:

• Turbine Building Basement.

This inspection constituted one internal flooding inspection sample as defined in IP 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

.1 Annual Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensees testing of EDG 12 jacket water, lube oil, and air cooler heat exchangers. The inspectors assessed the as-found and as-left condition of the heat exchangers by direct observation and document reviews to verify no deficiencies existed that would adversely impact the heat exchangers ability to transfer heat to the EDG service water system and to ensure the licensee was adequately addressing problems that could affect the performance of the heat exchangers. The inspectors reviewed the licensees observations as compared against the acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. The inspectors also verified the test acceptance criteria considered differences between test conditions, design conditions, and testing conditions.

This inspection constituted one annual heat sink performance inspection sample as defined in IP 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

The inspectors observed licensed operators during simulator training on July 23. The inspectors assessed the operators response to the simulated events focusing on alarm response, command and control of crew activities, communication practices, procedural adherence, and implementation of Emergency Plan requirements. The inspectors also observed the post-training critique to assess the ability of licensee evaluators and the operating crew to self-identify performance deficiencies. The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.

This inspection constituted one quarterly licensed operator requalification program simulator inspection sample as defined in IP 71111.11.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

On September 9, the inspectors observed licensed operators in the Control Room performing a plant shutdown in preparation for a planned maintenance outage. The activity required heightened awareness, additional detailed planning, and involved increased operational risk. 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 procedures;

• control board (or equipment) manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions.

The performance in these areas was compared to pre-established operator action expectations, procedural compliance, and task completion requirements.

This inspection constituted one quarterly licensed operator heightened activity/risk inspection sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the licensee's handling of selected degraded performance issues involving the following risk-significant structures, systems, and components (SSCs):

• RHR system, and

• Turbine Control Valve Actuators.

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the SSCs. Specifically, the inspectors independently verified the licensee's handling of SSC performance or condition problems in terms of:

• appropriate work practices;

• identifying and addressing common cause failures;

• scoping of SSCs in accordance with 10 CFR 50.65(b);

• characterizing SSC reliability issues;

• tracking SSC unavailability;

• trending key parameters (condition monitoring);

• 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification; and

• appropriateness of performance criteria for SSC functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSC functions classified (a)(1).

In addition, the inspectors verified problems associated with the effectiveness of plant maintenance were entered into the licensee's corrective action program with the appropriate characterization and significance. Selected CARDS were reviewed to verify corrective actions were appropriate and implemented as scheduled.

This inspection constituted two quarterly maintenance effectiveness inspection samples as defined in IP 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify the appropriate risk assessments were performed prior to removing equipment for work:

• planned maintenance during the week of July 8-12 on Emergency Equipment Cooling Water/Service Water; and

• planned maintenance during the week of July 22-26 on Division 1 Containment Spray system, Division 1 Non-interruptible Air Supply system, and Division 1 Control Center Heating, Ventilation, and Air Conditioning system.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each of the above activities, the inspectors reviewed the scope of maintenance work in the plants daily schedule, reviewed Control Room logs, verified plant risk assessments were completed as required by 10 CFR 50.65(a)(4) prior to commencing maintenance activities, discussed the results of the assessment with the licensees Probabilistic Risk Analyst and/or Shift Technical Advisor, and verified plant conditions were consistent with the risk assessment assumptions. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid, redundant safety-related plant equipment necessary to minimize risk was available for use, and applicable requirements were met.

In addition, the inspectors verified maintenance risk related problems were entered into the licensees corrective action program with the appropriate significance characterization. Selected CARDS were reviewed to verify corrective actions were appropriate and implemented as scheduled.

This inspection constituted two maintenance risk assessments inspection samples as defined in IP 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

a. Inspection Scope

The inspectors reviewed the following issues:

• Operational Decision Making Issue (ODMI)13-005, "Indications of Fuel Defect:

PO13-02 Restart;"

• CARD 13-25378, E5150F054 RCIC [Reactor Core Isolation Cooling] Turbine Steam Drain Bypass Valve Is Open to Backseat and Minimize Steam Leak; and

• CARD 13-26320, Gasket on Blowout Panel in Turbine Building Steam Tunnel Mezzanine Has Shifted Causing a Gap; and

• Water Found on Drywell Cooler No. 4.

The inspectors selected these potential operability/functionality issues based on the risk significance of the associated components and systems. The inspectors verified the conditions did not render the associated equipment inoperable or result in an unrecognized increase in plant risk. When applicable, the inspectors verified the licensee appropriately applied TS limitations, appropriately returned the affected equipment to an operable status, and reviewed the licensees evaluation of the issue with respect to the regulatory reporting requirements. 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 evaluation. When applicable, the inspectors also verified the licensee appropriately assessed the functionality of SSCs that perform specified functions described in the UFSAR, Technical Requirements Manual, Emergency Plan, Fire Protection Plan, regulatory commitments, or other elements of the current licensing basis when degraded or nonconforming conditions were identified.

In addition, the inspectors verified that problems related to the operability or functionality of safety-related plant equipment were entered into the licensees corrective action program with the appropriate characterization and significance. Selected CARDS were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted four operability determination inspection samples as defined in IP 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed the following plant temporary modification:

• TM 13-0001, Install additional monitoring equipment to monitor the south reactor feed pump/turbine; and TM 13-0002, Install additional monitoring equipment to monitor the north reactor feed pump/turbine.

The inspectors reviewed the temporary modifications and the associated 10 CFR 50.59 screening/evaluations against applicable system design basis documents, including the UFSAR and the TSs to verify whether applicable design basis requirements were satisfied. The inspectors reviewed the Control Room logs and interviewed engineering and operations department personnel to understand the impact that implementation of the temporary modification had on operability and availability of the affected system.

The inspectors also reviewed a sample of CARDS pertaining to temporary modifications to verify problems were entered into the licensees corrective action program with the appropriate significance characterization, and the corrective actions were appropriate.

This inspection constituted one temporary modification inspection sample as defined in IP 71111.18.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors reviewed the engineering analyses, modification documents, and design change information associated with the following permanent plant modifications:

• Engineering Design Package (EDP) 37014, Restoration of the South Reactor Feed Pump/Turbine Mechanical Isolations; and

• EDP 36983, Instrumentation and Controls Electrical Restoration of the South Reactor Feed Pump Turbine.

During this inspection, the inspectors evaluated the implementation of the design modifications and verified, as appropriate:

• the compatibility, functional properties, environmental qualification, seismic qualification, and classification of materials and replacement components were acceptable;

• the structural integrity of the SSCs would be acceptable for accident/event conditions;

• the implementation of the modification did not impair key safety functions;

• no unintended system interactions occurred;

• the affected significant plant procedures, such as normal, abnormal, and emergency operating procedures, testing and surveillance procedures, and training were identified and necessary changes were completed;

• the design and licensing documents were either updated or were in the process of being updated to reflect the modification;

• the changes to the facility and procedures as described in the UFSAR were appropriately reviewed and documented in accordance with 10 CFR 50.59;

• the system performance characteristics, including energy needs affected by the modification continued to meet the design basis;

• the modification test acceptance criteria were met; and

• the modification design assumptions were appropriate.

Completed activities associated with the implementation of the modification, including testing, were also inspected, and the inspectors discussed the modification with the responsible engineering and operations staff.

In addition, the inspectors verified problems associated with plant modifications were entered into the licensee's corrective action program with the appropriate characterization and significance. Selected CARDS were reviewed to verify corrective actions were appropriate and implemented as scheduled.

The inspection of these two modifications was continued from the first quarter of this year and do not count as inspection samples under IP 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance testing activities to verify procedures and test activities were adequate to ensure system operability and functional capability:

• Work Order (WO) 36010245, Implement On-line Noble Chemistry Application;

• WO 33275008, Perform 24-Month Tasks per 35.307.017 on EDG 12;

• WO 36173537, Inspect, Clean Contacts, Test A71B-K4B HFA;

• WO 32024772, Hydraulic Control Unit 26-19 Accumulator Replacement; and

• CRDM 06-47, 14-07, and 34-39 Replacements (Multiple WOs).

The inspectors reviewed the scope of the work performed and evaluated the adequacy of the specified post-maintenance testing. The inspectors verified the post-maintenance testing was performed in accordance with approved procedures; the procedures contained clear acceptance criteria, which demonstrated operational readiness, and the acceptance criteria was met; appropriate test instrumentation was used; the equipment was returned to its operational status following testing; and, the test documentation was properly evaluated.

In addition, the inspectors reviewed corrective action program documents associated with post-maintenance testing to verify identified problems were entered into the licensee's corrective action program with the appropriate characterization. Selected CARDs were reviewed to verify the corrective actions were appropriate and implemented as scheduled.

This inspection constituted five post-maintenance testing inspection samples as defined in IP 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

.1 Planned Outage PO-13-02

a. Inspection Scope

The inspectors evaluated the licensees conduct of outage activities during planned maintenance outage PO-13-02, which began on September 9. The licensee shut down the unit to replace the south reactor feedwater pump and to complete additional planned maintenance work. The unit was restarted on September 21 and reached full power on October 2.

The inspectors reviewed configuration management to verify the licensee maintained defense-in-depth commensurate with the shutdown risk plan and reviewed major outage work activities to ensure correct system lineups were maintained for key mitigating systems. The inspectors verified the licensee appropriately established plant conditions and satisfied TS requirements prior to and while performing operations with the potential to drain the reactor vessel. Other major outage activities evaluated included the licensee's control of the following:

• containment penetrations in accordance with the TSs;

• SSCs that could cause unexpected reactivity changes;

• flow paths, configurations, and alternate means for Reactor Coolant System (RCS) inventory addition;

• SSCs (e.g., control rod drive mechanism replacements) that could cause a loss of RCS inventory;

• RCS level instrumentation;

• radiological work practices;

• switchyard activities and the configuration of electrical power systems in accordance with the TSs and shutdown risk plan; and

• SSCs required for decay heat removal and for establishing alternate means for decay heat removal, including instrumentation.

The inspectors observed portions of the plant cooldown, including the transition to shutdown cooling, to verify the licensee controlled the plant cooldown in accordance with the TSs. The inspectors also observed portions of the restart activities, including reactor startup and plant heat up, to verify TS requirements and administrative procedure requirements were met prior to changing operational modes or plant configurations.

Major restart inspection activities performed included:

• verification that RCS boundary leakage requirements were met prior to entry into Mode 2;

• verification that primary and secondary containment integrity was established prior to entry into Mode 2; and

• inspection of the drywell to assess material condition and search for loose debris, which, if present, could block floor drains or be transported to the torus.

The inspectors interviewed operations, engineering, work control, radiological protection, and maintenance department personnel and reviewed selected procedures and documents. The inspectors accompanied the licensee on seismic walkdowns to areas previously inaccessible, associated with Temporary Instruction (TI) 2515/188, Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns.

In addition, the inspectors reviewed a sample of issues the licensee entered into the corrective action program related to outage activities to verify identified problems were being entered with the appropriate characterization and significance. Selected CARDs were reviewed to verify the corrective actions were appropriate and implemented as scheduled.

This inspection constituted one other outage inspection sample as defined in IP 71111.20.

b. Findings

No findings were identified.

1R22 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:

• WO 33963901, Perform 44.030.280, Emergency Core Cooling System (ECCS)-Reactor Steam Dome Pressure RHR Loop Select Permissive Division 2, Channel Functional Test (routine);

• WO 33573821, Perform 24.3007.33, EDG 14, 24-Hour Run Followed by Hot Fast Restart (routine);

• Procedure 24.202.01, HPCI [High Pressure Coolant Injection] Pump and Valve Operability Test at 1025 PSI [Pounds-per-Square-Inch] (inservice testing);

• Procedure 24.000.02, Shiftly, Daily, and Weekly Required Surveillances, 1, Eight-hour - Mode 1, 2, 3 Control Room (RCS leakage);

• Procedure 24.206.02, Section 5.1, RCIC Cold Shutdown Valve Operability Test (inservice testing); and

• Procedure N30N179B-SS, HP [High Pressure] Control Valve No. 2 Position Indication (routine).

The inspectors observed selected portions of the test activities to verify the testing was accomplished in accordance with plant procedures. The inspectors reviewed the test methodology and documentation to verify equipment performance was consistent with safety analysis and design basis assumptions, 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, and appropriate testing acceptance criteria were satisfied. When applicable, the inspectors also verified test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable.

In addition, the inspectors verified surveillance testing problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected CARDs were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted three routine surveillance tests, two inservice tests, and one RCS leakage detection test for a total of six surveillance testing inspection samples as defined in IP 71111.22.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on August 20 to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. This drill was planned to be evaluated and was included in performance indicator data regarding drill and exercise performance. The inspectors observed emergency response operations in the Control Room Simulator and the Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensees drill critique to compare any inspector-observed weaknesses with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensees staff was properly identifying weaknesses and entering them into the corrective action program.

This inspection constituted one emergency preparedness drill inspection sample as defined in IP 71114.06.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

These inspection activities supplement those documented in Inspection Report 05000341/2013002 and constitute one complete inspection sample as defined in IP 71124.01.

.1 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors reviewed the last two radiological surveys from selected plant areas and evaluated whether the thoroughness and frequency of the surveys were appropriate for the given radiological hazard.

The inspectors selected the following radiologically risk-significant work activities that involved exposure to radiation:

• fuel pool filter packaging and disposal activities;

• traverse incore probe runs; and

• high radiation material transfer within the protected area.

For these work activities, the inspectors assessed whether the pre-work surveys performed were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if hazards were properly identified, including the following:

• identification of hot particles;

• the presence of alpha emitters;

• the potential for airborne radioactive materials, including the potential presence of transuranics and/or other hard-to-detect radioactive materials (This evaluation may include licensee planned entry into non-routinely entered areas subject to previous contamination from failed fuel.);

• the hazards associated with work activities that could suddenly and severely increase radiological conditions and the licensee has established a means to inform workers of changes that could significantly impact their occupational dose; and

• severe radiation field dose gradients that can result in non-uniform exposures of the body.

b. Findings

No findings were identified.

.2 Radiation Worker Performance (02.07)

a. Inspection Scope

The inspectors observed radiation worker performance with respect to stated radiation protection work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the radiation work permit controls/limits in place and whether their performance reflected the level of radiological hazards present.

The inspectors reviewed radiological CARDs since the last inspection that found the cause of the event to be human performance errors. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. The inspectors discussed with the radiation protection manager any problems with the corrective actions planned or taken.

b. Findings

No findings were identified.

.3 Radiation Protection Technician Proficiency (02.08)

a. Inspection Scope

The inspectors observed the performance of the radiation protection technicians with respect to all radiation protection work requirements. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the radiation work permit controls/limits and whether their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities.

The inspectors reviewed radiological CARDs since the last inspection that found the cause of the event to be radiation protection technician error. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08) This inspection constituted one complete inspection sample as defined in IP 71124.08.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the solid radioactive waste system description in the UFSAR, the Process Control Program (PCP), and the recent Radiological Effluent Release Report for information on the types, amounts, and processing of radioactive waste disposed.

The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensees performance and inform the smart sampling inspection planning.

b. Findings

No findings were identified.

.2 Radioactive Material Storage (02.02)

a. Inspection Scope

The inspectors selected areas where containers of radioactive waste are stored and evaluated whether the containers were labeled in accordance with 10 CFR 20.1904, Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to Labeling Requirements, as appropriate.

The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20, Standards for Protection Against Radiation. For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, Security of Stored Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.

The inspectors evaluated whether the licensee established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.

The inspectors selected containers of stored radioactive material and assessed for signs of swelling, leakage, and deformation.

b. Findings

No findings were identified.

.3 Radioactive Waste System Walkdown (02.03)

a. Inspection Scope

The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in the UFSAR, Offsite Dose Calculation Manual (ODCM), and PCP.

The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment, which is not in service or abandoned in place, would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure.

The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, Changes, Tests, and Experiments.

The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes, from what is described in the UFSAR, were reviewed and documented in accordance with 10 CFR 50.59, as appropriate, and to assess the impact on radiation doses to members of the public.

The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, Waste Classification.

For those systems that provide tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing.

The inspectors assessed whether the licensees PCP correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid).

b. Findings

No findings were identified.

.4 Waste Characterization and Classification (02.04)

a. Inspection Scope

The inspectors selected the following radioactive waste streams for review:

• Bead Resin, May 15, 2012;

• Condensate Resin, October 4, 2012; and

• Fuel Pool Heat Exchanger Cation Resin No.1, August 19, 2010.

For the waste streams listed above, the inspectors assessed whether the licensees radiochemical sample analysis results were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated whether the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analyses for the selected radioactive waste streams.

The inspectors evaluated whether changes to plant operational parameters were taken into account to:

(1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and

(2) assure waste shipments continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above.

The inspectors evaluated whether the licensee had established and maintained an adequate quality assurance program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste Characteristics.

b. Findings

No findings were identified.

.5 Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for cask loading and closure procedures were consistent with the vendors current approved procedures.

The inspectors assessed whether the shippers were knowledgeable of the shipping regulations and whether shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to:

• the licensees response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, dated August 10, 1979; and

• Title 49 CFR Part 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans, Subpart H, Training.

Due to limited opportunities for direct observation, the inspectors reviewed the technical instructions presented to workers during routine training. The inspectors assessed whether the licensees training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.

b. Findings

No findings were identified.

.6 Shipping Record (02.06)

a. Inspection Scope

The inspectors evaluated whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number for the following radioactive shipments:

• EF2-11-062, Radioactive Waste Shipment - Resin, June 14, 2011;

• EF2-11-106, Radioactive Material Shipment Equipment and Source, November 16, 2011;

• EF2-12-072, Radioactive Waste Shipment - Resin, June 21, 2012;

• EF2-12-087, Radioactive Material Shipment Equipment, August 30, 2012; and

• EF2-13-001, Radioactive Waste - Resin, June 7, 2013.

Additionally, the inspectors assessed whether the shipment marking, labeling, and placarding were consistent with the information in the shipping documentation.

b. Findings

No findings were identified.

.7 Identification and Resolution of Problems (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensees corrective action program. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involved radioactive waste processing, handling, storage, and transportation.

The inspectors reviewed results of selected audits performed since the last inspection of this program and evaluated the adequacy of the licensees corrective actions for issues identified during those audits.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, and Occupational and Public Radiation Safety

4OA1 Performance Indicator Verification

.1 Review of Submitted Quarterly Data

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the second quarter 2013 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program."

This inspection was not considered to be an inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index (MSPI) - High Pressure Injection Systems

a. Inspection Scope

The inspectors reviewed a sample of plant records and data against the reported MSPI - High Pressure Injection Systems Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, Licensee Event Reports (LERs), and maintenance and test data from July 2012 through June 2013, to validate the accuracy of the performance indicator data reported. 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 corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.

This inspection constituted one MSPI - High Pressure Injection Systems Performance Indicator verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

.3 MSPI - Heat Removal System

a. Inspection Scope

The inspectors reviewed a sample of plant records and data against the reported MSPI - Heat Removal System Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from July 2012 through June 2013 to validate the accuracy of the performance indicator data reported. 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 corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.

This inspection constituted one MSPI - Heat Removal System Performance Indicator verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

.4 MSPI - Emergency Alternating Current Power System

a. Inspection Scope

The inspectors reviewed a sample of plant records and data against the reported MSPI -

Emergency Alternating Current Power System Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from April 2012 through June 2013 to validate the accuracy of the performance indicator data reported. 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 corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.

This inspection constituted one MSPI - Emergency Alternating Current Power System Performance Indicator verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

.5 RCS Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the RCS Specific Activity Performance Indicator for the third quarter 2012 through the second quarter 2013. The inspectors used performance indicator definitions and guidance in the NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to determine the accuracy of the performance indicator data reported during this period. The inspectors reviewed the licensees RCS chemistry samples, TS requirements, CARDs, LERs, and NRC integrated inspection reports to validate the accuracy of the submittals. The inspectors also reviewed the licensees corrective action program database to determine if any problems had been identified with the performance indicator 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 an RCS sample.

This inspection constituted one RCS Specific Activity Performance Indicator verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

.6 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the Occupational Radiological Occurrences Performance Indicator for the third quarter 2012 through the second quarter 2013. The inspectors used performance indicator definitions and guidance in the NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to determine the accuracy of the performance indicator data reported during this period.

The inspectors reviewed the licensees assessment of the performance indicator for occupational radiation safety to determine if performance indicator related data was adequately assessed and reported. To assess the adequacy of the licensees performance indicator 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 personal dosimetry dose rate and accumulated dose alarms 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.

This inspection constituted one Occupational Exposure Control Effectiveness Performance Indicator verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

.7 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the Radiological Effluent Technical Specification/Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent Occurrences Performance Indicator for the third quarter 2012 through the second quarter 2013. The inspectors used performance indicator definitions and guidance contained in the NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to determine the accuracy of the performance indicator data reported during this period. The inspectors reviewed the licensees corrective action program database and selected individual CARDs generated since this performance 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 to determine if performance indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose.

This inspection constituted one RETS/ODCM Radiological Effluent Occurrences Performance Indicator verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As 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 corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, they are not discussed in this report.

This inspection was not considered to be an inspection sample as defined in IP 71152.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 TI 2515/182 - Review of the Industry Initiative to Control Degradation of Underground

Piping and Tanks

a. Inspection Scope

Leakage from buried and underground pipes has resulted in ground water contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, NEI 09-14, Guideline for the Management of Buried Piping Integrity, (ADAMS Accession No. ML103090142), to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122), with an expanded scope of components, which included underground piping that was not in direct contact with the soil and underground tanks.

On November 17, 2011, the NRC issued TI 2515/182, Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, to gather information related to the industrys implementation of this initiative.

From September 16-20, 2013, the inspectors conducted a review of records and procedures related to the licensees program for buried pipe, underground pipe, and tanks in accordance with Phase II of TI-2515/182. This review was done to confirm that the licensees program contained attributes consistent with Sections 3.3 A and 3.3 B of NEI 09-14 and to confirm that these attributes were scheduled and/or completed by the NEI 09-14, Revision 1, deadlines. The inspectors interviewed licensee staff responsible for the buried pipe program and reviewed documentation to determine whether the program was managed effectively.

Based upon the scope of the review described above, Phase II of TI-2515/182 was completed.

b. Observations The licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraph 03.02.a of the TI and it was confirmed that activities which correspond to completion dates specified in the program which have passed since the Phase I inspection was conducted have been completed. Additionally, the licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraph 03.02.b of the TI and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-20 11-11-16.pdf, was submitted to the NRC Headquarters staff.

c. Findings

No findings were identified.

4OA6 Management Meetings

.1 Resident Inspectors Exit Meeting

The inspectors presented the inspection results to Mr. T. Conner and other members of the licensees staff at the conclusion of the inspection on October 3, 2013. Proprietary information was examined during this inspection, but is not specifically discussed in this report.

.2 Interim Exit Meetings

Interim exits were conducted for:

• The inspection results for the areas of Radiological Hazard Assessment and Exposure Controls; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation; and RCS Specific Activity, Occupational Exposure Control Effectiveness, and RETS/ODCM Radiological Effluent Occurrences Performance Indicator Verification with Mr. Z. Rad on July 12, 2013.

• The Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (TI-2515/182, Phase II) with Ms. J. Ford and other members of the licensee staff on September 19, 2013.

The inspectors confirmed none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

S. Bollinger, Manager, Performance Improvement

M. Brooks, Buried Piping Program Owner

M. Caragher, Director, Nuclear Engineering

W. Colonnello, Director, Nuclear Support

T. Conner, Vice-President, Nuclear Generation

J. Davis, Manager, Training

J. Ford, Director, Organization Effectiveness

S. Hassoun, Supervisor, Licensing and Environment

D. Hemmele, Superintendent, Operations

E. Kokosky, Manager, Nuclear Quality Assurance

R. LaBurn, Manager, Radiation Protection

C. McKinney, Engineering

H. Michael, Engineering

L. Petersen, Manager, Plant Support Engineering

G. Piccard, Manager, Systems Engineering

Z. Rad, Manager, Licensing

R. Salmon, Supervisor, Regulatory Compliance

K. Scott, Plant Manager

B. Stephen, Manager, Outage Scheduling

G. Strobel, Manager, Operations

J. Thorson, Manager, Performance Engineering

H. Torberg, Manager, Security

B. Weber, Principal Technical Specialist

H. Yeldell, Manager, Maintenance

Attachment

LIST OF ITEMS

Opened

None

Closed

None

Discussed

None Attachment