Text

IR 05000346/2015002; on 4/1/15 - 6/30/15; Davis-Besse Nuclear Power Station; Routine Quarterly Integrated IR
	ML15202A203
Person / Time
Site:	Davis Besse
Issue date:	07/21/2015
From:	Jamnes Cameron; Reactor Projects Region 3 Branch 4
To:	Boles B; FirstEnergy Nuclear Operating Co
References
	IR 2015002
	Download: ML15202A203 (56)
	v • d • e

UNITED STATES uly 21, 2015

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION NRC INTEGRATED INSPECTION REPORT 05000346/2015002

Dear Mr. Boles:

On June 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on June 30, 2015, with you and other members of your staff.

Based on the results of this inspection, no findings were identified. One licensee-identified violation which was determined to be of very low safety significance is documented in Section 4OA7 of this report. The NRC is treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2.a of the Enforcement Policy.

In accordance with Title 10 of the Code of Federal Regulations (10 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 NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects Docket No. 50-346 License No. NPF-3

Enclosure:

Inspection Report 05000346/2015002 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-346 License No: NPF-3 Report No: 05000346/2015002 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: April 1, 2015, through June 30, 2015 Inspectors: D. Kimble, Senior Resident Inspector T. Briley, Resident Inspector P. Lee, Ph.D., CHP, Health Physicist M. Mitchell, Health Physicist J. Rutkowski, Project Engineer A. Schwab, Reactor Engineer Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000346/2015002; 4/1/15-6/30/15; Davis-Besse Nuclear Power Station;

Routine Quarterly Integrated IR.

This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Cross-cutting aspects are determined using Inspection Manual Chapter (IMC) 0310, Aspects Within the Cross-Cutting Areas effective date December 4, 2014. All violations of U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

A violation of very low safety significance that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program (CAP). This violation and CAP tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

The unit began the inspection period operating at full power. With the exception of small power maneuvers (e.g., reductions in power of about 10 percent or less) to facilitate planned testing evolutions, the unit continued to operate at or near full power until May 9, 2015. On that day at about 7:09 p.m., the unit was manually tripped from approximately 30 percent power in response to a steam line rupture in the turbine building (see Section 4OA3 for additional details). Following repairs during the ensuing forced maintenance outage (see Section 1R20 for additional details), the reactor was restarted on May 11, 2015, and the unit returned to operation at full power on May 14, 2015. The unit then operated at or near full power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

During the weeks ending April 18, 2015, and April 25, 2015, 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 that 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, but were not limited to:

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.

Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed Corrective Action Program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures.

These reviews by the inspectors constituted a single summer readiness of offsite and alternate AC power systems inspection sample as defined in Inspection Procedure (IP)71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Quarterly Partial System Alignment Verifications

a. Inspection Scope

The inspectors performed partial system physical alignment verifications of the following risk significant systems:

Verification of the alignment for the station blackout diesel generator when Emergency Diesel Generator (EDG) No. 2 was out of service for planned testing during the week ending April 25, 2015;

Verification of the alignment for EDG No. 1 when EDG No. 2 was out of service for planned testing during the week ending May 23, 2015; and

Verification of the alignment for Auxiliary Feedwater (AFW) Train No. 2 when AFW Train No. 1 was out of service for a scheduled maintenance work window during the week ending May 30, 2015.

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, Updated Safety Analysis Report (USAR), Technical Specification (TS)requirements, outstanding work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have 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 that there were no obvious deficiencies. The inspectors also verified that 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 Attachment to this report.

These activities by the inspectors constituted three partial system alignment verification inspection samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

.1 Quarterly Fire Protection Zone Inspections

a. Inspection Scope

The inspectors conducted fire protection zone inspection tours which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk significant plant areas:

High Voltage Switchgear Room A (Room 325 - Fire Area S) during the week ending May 2, 2015;

High Voltage Switchgear Room B (Room 323 - Fire Area O) during the week ending May 2, 2015;

Auxiliary Shutdown Panel and Transfer Switch Room (Room 324 - Fire Area R)during the week ending May 2, 2015;

Low Level Radwaste Storage Building (Rooms 389 through 397 - Fire Area RW)during the week ending May 2, 2015; and

Emergency Core Cooling System Room No. 2 (Rooms 113, 114, 115, and 125 -

Fire Area A and portions of Fire Area AB) during the week ending May 2, 2015.

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 that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that 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 Attachment to this report.

These activities constituted five quarterly fire protection zone inspection tour samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

.1 Underground Bunkers/Manholes

a. Inspection Scope

During the week ending June 20, 2015, the inspectors conducted a review of underground bunkers/manholes subject to flooding that contained electrical cables. The inspectors reviews included the following underground bunkers/manholes subject to flooding:

Electrical Manholes SA1/SA2; and

Electrical Manholes SB1/SB2.

The inspectors checked for submerged cables, that splices were intact, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as sump pumps, the inspectors verified that the devices were functional and that any level alarm circuits were set appropriately to ensure that the cables would not be submerged. In those areas without dewatering devices, the inspectors verified that drainage of the area was available, or that the cables were qualified for submergence conditions. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues to verify the adequacy of the corrective actions. Specific documents reviewed during this inspection are listed in the Attachment to this report.

The inspectors reviews of these underground bunkers/manholes constituted a single inspection sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Resident Inspector Quarterly Observation of Operator Activities in the Control Room and

in the Plant

a. Inspection Scope

During the course of the inspection period, the inspectors performed numerous observations of operator performance in the plants control room and in the plant to verify that operator performance was adequate and that plant evolutions were being conducted in accordance with approved plant procedures. Specific activities observed that involved a heightened tempo of activities or periods of elevated risk included, but were not limited to:

Implementation of changes to the integrated control system (ICS) and associated unit power maneuvers during the weeks ending May 2, 2015, and June 20, 2015;

Periodic diverse scram system and reactor trip breaker testing and associated unit power maneuvers during the weeks ending May 9, 2015, and June 20, 2015;

Transient and post-trip response following the rupture of a high pressure steam line in the turbine building during the week ending May 9, 2015 (see Section 4OA3 for additional details);

Unit recovery and startup from a forced outage during the week ending May 16, 2015 (see Section 1R20 for additional details); and

Emergent shutdown of Circulating Water Pump No. 4 following a rapid increase in circulating water canal screen differential level during the week ending May 23, 2015.

The inspectors evaluated the following areas during the course of the control room and in-plant observations:

Licensed operator performance;

The clarity and formality of communications;

The ability of the crew to take timely and conservative actions;

The crews prioritization, interpretation, and verification of annunciator alarms;

The correct use and implementation of normal operating, annunciator alarm response, and abnormal operating procedures by the crew;

Control board manipulations;

The oversight and direction provided by on-watch Senior Reactor Operators (SROs) and plant management personnel; and

The ability of the crew to identify and implement appropriate TS 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.

These observation activities by the inspectors of operator performance in the stations control room and in the plant constituted a single quarterly inspection sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

Shield Building Condition Monitoring Program, with particular emphasis on the licensee's summer 2015 concrete inspection campaign; and

Secondary Piping Condition Monitoring Program, with particular emphasis on the number and extent of active secondary plant steam leaks.

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 were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

.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:

Corrective maintenance for issues associated with Main Turbine Electronic Trip Device No. 3B during the week ending April 25, 2015;

Corrective maintenance for a leak on the 2,000 pounds per square inch gauge air system for 345 KV Air Circuit Breaker (ACB) No. 34562 during the week ending May 2, 2015; and

Corrective maintenance to adjust steam generator operate range level indication during the weeks ending May 23, 2015 through June 13, 2015; These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that 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 that 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. Specific documents reviewed during this inspection are listed in the Attachment to this report.

The inspectors' review of these maintenance risk assessments and emergent work control activities constituted three inspection samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

The operability of the plant's once-through steam generators with respect to higher than nominal operating range levels, as discussed in CRs 2015-05633 and 2015-01595;

The operability of the plant's main steam isolation valves following discovery that closure times did not meet the expected values described in applicable procedures, as discussed in CR 2015-06720; and

The seismic qualifications of a heavy drill rig being used to facilitate construction activities in close proximity to the station's borated water storage tank, and other safety-related components, as described in Engineering Evaluation Request (EER) 600965176.

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 that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and USAR 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 verified, where applicable, that the bounding limitations of the evaluations were valid.

Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment to this report.

The review of these operability determinations and functionality assessments by the inspectors constituted three inspection samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

.2 Periodic Review of Operator Workarounds

a. Inspection Scope

Operator workarounds are operator actions taken to compensate for degraded or non-conforming conditions. Operator workarounds that cannot be implemented effectively can contribute to an increase in overall plant risk. As a result, the inspectors verified that the licensee is identifying operator workarounds at an appropriate threshold, entering them into the CAP, and addressing them in a manner that effectively manages the related adverse effects. As part of the review, the inspectors considered all existing plant conditions and the cumulative impact of the entire population of operator workarounds put in place by the licensee.

During the weeks ending April 11, 2015, and April 18, 2015, the inspectors evaluated the licensee's operator workarounds with respect to mitigating systems to determine if the functions of the mitigating systems were adversely impacted. Additionally, the inspectors assessed whether or not the operator workarounds had adversely impacted any operators ability to implement abnormal or emergency operating procedures. The inspectors placed particular emphasis on any operator workarounds that had not been effectively evaluated by the licensee; that had been formalized or proceduralized as the long-term corrective actions for a degraded or nonconforming condition (and therefore may not have been properly tracked by the licensee); and that may have increased the potential for human error, such as operator workarounds that:

Required operations that were not consistent with current training and system knowledge;

Required a change from longstanding operational practices;

Required operation of a system or component in a manner that was inconsistent with similar systems or components;

Created the potential for the compensatory action to be performed on equipment or under conditions for which it was not intended;

Impaired access to required indications, increased dependence on oral communications, or impacted the timeliness of time-critical event mitigating actions under adverse environmental conditions;

Required the use of equipment and interfaces that had not been designed with consideration of the task being performed;

Required the licensee to assess and manage an increase in risk; or

Required a license amendment in accordance with 10 CFR 50.59.

Documents reviewed are listed in the Attachment to this report.

These activities by the inspectors constituted a single operator workarounds review inspection sample as required by IP 71111.15, Section 02.01(a).

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

.1 Permanent Plant Modification

a. Inspection Scope

The inspectors reviewed the following ongoing change to the facility:

Engineering Change Package (ECP) No. 13-0195-000: Emergency Feedwater Facility, with particular emphasis on activities associated with construction of the facility's below grade secant wall.

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation documents against the design basis, the USAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of any safety-related systems, or systems important to safety. The inspectors conducted a significant number of field observations of the ongoing construction activities to ensure that the modification was installed as directed and consistent with the design control documents; that the modification operated as expected; and that the ongoing construction activities associated with the modification did not impact the operability of any interfacing or nearby systems. The inspectors verified that relevant procedure, design, and licensing documents were properly updated, as applicable. Finally, the inspectors discussed the plant modification with operations, engineering, and training department personnel to ensure that the individuals were aware of how the operation with the modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.

The inspectors review of this permanent plant modification constituted a single inspection sample as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

.1 Quarterly Resident Inspector Observation and Review of Post-Maintenance Testing

Activities

a. Inspection Scope

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

Nondestructive testing associated with repairs to a failed vent line connecting No. 1 Moisture Separator Reheater (MSR) and the Second Stage Reheater Drain Tank during the week ending May 16, 2015;

Operational and functional testing of the No. 2 Station Air Compressor following corrective maintenance during the week ending May 23, 2015;

Operational and functional testing of the rod position indication for Control Rod Drive Mechanism 3-2 following corrective maintenance during the week ending May 23, 2015;

Operational and functional testing of the station's motor-driven feedwater pump following planned maintenance during the week ending June 20, 2015; and

Parameter testing associated with replacement of Module No. ICSFW5212A/B, which provides the unit with rapid feedwater temperature reduction following a plant trip, during the week ending June 20, 2015.

These activities were selected based upon the SSC'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 TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with the PMTs to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety.

Documents reviewed are listed in the Attachment to this report.

The inspectors reviews of these activities constituted five PMT inspection samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R20 Outage Activities

Main article: IP 71111.20

.1 May 2015 Forced Maintenance Outage

a. Inspection Scope

The inspectors evaluated outage activities for a forced maintenance outage that began with a manual reactor trip at approximately 7:09 p.m. on May 9, 2015, as a result of a steam line rupture in the turbine building (see Section 4OA3.1 for event details).

Following completion of various plant repairs associated with the event, the reactor was restarted on May 11, 2015, and the unit returned to full power on May 14, 2015.

The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule. The inspectors reviewed plant records associated with the reactor trip and steam line rupture in the turbine building. Outage equipment configuration, risk management, electrical lineups, selected clearances, control and monitoring of decay heat removal, personnel fatigue management, startup activities, and identification and resolution of problems associated with the outage were also reviewed and selectively observed by the inspectors.

Documents reviewed are listed in the Attachment to this report.

These observations and reviews by the inspectors constituted a single other (i.e.,

non-refueling) outage sample as defined in IP 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the results for the following testing 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:

Periodic functional testing and calibration of pressure switches associated with Main Feed Pump Nos. 1 and 2 hydraulic oil and Anticipatory Reactor Trip System Channel No. 3 during the week ending May 2, 2015 (routine);

Monthly testing of AFW Train No. 1 during the week ending May 2, 2015 (routine);

Monthly logic output testing for Safety Features Actuation System Channel No. 1 during the week ending May 2, 2015 (routine);

Periodic functional testing and calibration of pressure switches associated with Steam Feed Rupture Control System Channel No. 1 during the week ending May 2, 2015 (routine);

Quarterly No. 2 Makeup Pump surveillance and inservice test during the week ending May 23, 2015 (inservice test);

Quarterly containment entry and visual inspections during the week ending June 20, 2015 (routine); and

Periodic 184-day fast start surveillance test of No. 2 EDG during the week ending June 20, 2015 (routine).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

Did preconditioning occur;

The effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

Acceptance criteria were clearly stated, demonstrated operational readiness, and were 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 was in accordance with TSs, the USAR, procedures, and applicable commitments;

That measuring and test equipment calibration was current;

That test equipment was used within the required range and accuracy;

That applicable prerequisites described in the test procedures were satisfied;

That 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;

That test data and results were accurate, complete, within limits, and valid;

That 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 (AMSE) code, and reference values were consistent with the system design basis;

Where applicable, that 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, that reference setting data were accurately incorporated in the test procedure;

Where applicable, that actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

That prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

That equipment was returned to a position or status required to support the performance of its safety functions; and

That all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

These activities conducted by the inspectors constituted six routine surveillance testing inspection samples and a single inservice testing inspection sample as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

Main article: IP 71124.01

These activities constituted a partial inspection sample as defined in IP 71124.01-05.

.1 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors observed locations where the licensee monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use, and evaluated whether the work was performed in accordance with plant procedures, and whether the procedures were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site. The inspectors assessed whether the radiation monitoring instrumentation had appropriate sensitivity for the types of radiation present.

The inspectors reviewed the licensees criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was guidance on how to respond to an alarm that indicates the presence of licensed radioactive material.

The inspectors reviewed the licensees procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors assessed whether or not the licensee has established a de facto release limit by altering the instruments typical sensitivity through such methods as raising the energy discriminator level or locating the instrument in a high-radiation background area.

The inspectors selected several sealed sources from the licensees inventory records, and assessed whether the sources were accounted for and verified to be intact.

The inspectors evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with Title 10, Code of Federal Regulations (CFR), Part 20.2207.

b. Findings

No findings were identified.

.2 Risk-Significant High-Radiation Area and Very-High Radiation Area Controls (02.06)

a. Inspection Scope

The inspectors discussed with the radiation protection manager the controls and procedures for high-risk, high-radiation areas and very-high radiation areas. The inspectors discussed methods employed by the licensee to provide stricter control of very-high radiation area access as specified in 10 CFR 20.1602, "Control of Access to Very-High Radiation Areas," and Regulatory Guide 8.38, "Control of Access to High and Very-High Radiation Areas of Nuclear Plants." The inspectors assessed whether any changes to licensee procedures substantially reduce the effectiveness and level of worker protection.

The inspectors discussed the controls in place for special areas that have the potential to become very-high radiation areas during certain plant operations with first-line health physics supervisors (or equivalent positions having backshift health physics oversight authority). The inspectors assessed whether these plant operations require communication beforehand with the health physics group, so as to allow corresponding timely actions to properly post, control, and monitor the radiation hazards including re-access authorization.

The inspectors evaluated licensee controls for very-high radiation areas and areas with the potential to become a very-high radiation area to ensure that an individual was not able to gain unauthorized access to the very-high radiation areas.

b. Findings

No findings were identified.

2RS2 Occupational As-Low-As-Reasonably-Achievable Planning and Controls

Main article: IP 71124.02

The inspectors' reviews documented in this section supplement those documented in NRC IR 05000346/2014002 (ADAMS Accession No. ML14113A073), and constitute a single complete inspection sample as defined in IP 71124.02-05.

.1 Radiological Work Planning (02.02)

.2 Engineering Controls (02.02)

a. Inspection Scope

The inspectors reviewed the licensees use of permanent and temporary ventilation to determine whether the licensee uses ventilation systems as part of its engineering controls (in lieu of respiratory protection devices) to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems, such as containment purge, spent fuel pool ventilation, and auxiliary building ventilation, and assessed whether the systems are used, to the extent practicable, during high-risk activities (e.g., using containment purge during cavity floodup).

The inspectors selected installed ventilation systems used to mitigate the potential for airborne radioactivity, and evaluated whether the ventilation airflow capacity, flow path (including the alignment of the suction and discharges), and filter/charcoal unit efficiencies, as appropriate, were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable.

The inspectors selected temporary ventilation system setups (high-efficiency particulate air/charcoal negative pressure units, down draft tables, tents, metal Kelly buildings, and other enclosures) used to support work in contaminated areas. The inspectors assessed whether the use of these systems is consistent with licensee procedural guidance, and the ALARA concept.

The inspectors reviewed airborne monitoring protocols by selecting installed systems used to monitor and warn of changing airborne concentrations in the plant, and evaluated whether the alarms and setpoints were sufficient to prompt licensee/worker action to ensure that doses are maintained within the limits of 10 CFR Part 20 and the ALARA concept.

The inspectors assessed whether the licensee had established trigger points (e.g., the Electric Power Research Institutes Alpha Monitoring Guidelines for Operating Nuclear Power Stations) for evaluating levels of airborne beta-emitting (e.g., plutonium-241) and alpha-emitting radionuclides.

b. Findings

No findings were identified.

.3 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

For those situations where it is impractical to employ engineering controls to minimize airborne radioactivity, the inspectors assessed whether the licensee provided respiratory protective devices such that occupational doses are ALARA. The inspectors selected work activities where respiratory protection devices were used to limit the intake of radioactive materials, and assessed whether the licensee performed an evaluation concluding that further engineering controls were not practical and that the use of respirators is ALARA. The inspectors also evaluated whether the licensee had established means (such as routine bioassay) to determine if the level of protection (protection factor) provided by the respiratory protection devices during use was at least as good as that assumed in the licensees work controls and dose assessment.

The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration or have been approved by the NRC per 10 CFR 20.1703(b). The inspectors selected work activities where respiratory protection devices were used. The inspectors evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or any conditions of their NRC approval.

The inspectors reviewed records of air testing for supplied-air devices and self-contained breathing apparatus bottles to assess whether the air used in these devices meets or exceeds Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they meet the minimum pressure and airflow requirements for the devices in use.

The inspectors selected several individuals qualified to use respiratory protection devices, and assessed whether they have been deemed fit to use the devices by a physician.

The inspectors selected several individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device as appropriate. Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence (loss of power, loss of air, etc.).

The inspectors chose multiple respiratory protection devices staged and ready for use in the plant or stocked for issuance for use. The inspectors assessed the physical condition of the device components (mask or hood, harnesses, air lines, regulators, air bottles, etc.) and reviewed records of routine inspection for each. The inspectors selected several of the devices and reviewed records of maintenance on the vital components (e.g., pressure regulators, inhalation/exhalation valves, hose couplings).

The inspectors reviewed the respirator vital components maintenance program to ensure that the repairs of vital components were performed by the respirators manufacturer.

b. Findings

No findings were identified.

.4 Self-Contained Breathing Apparatus for Emergency Use (02.04)

a. Inspection Scope

Based on the USAR, TS, and emergency operating procedure requirements, the inspectors reviewed the status and surveillance records of self-contained breathing apparatuses staged in-plant for use during emergencies. The inspectors reviewed the licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions.

The inspectors selected several individuals on control room shift crews and from designated departments currently assigned emergency duties (e.g., onsite search and rescue duties) to assess whether control room operators and other emergency response and radiation protection personnel (assigned in-plant search and rescue duties or as required by emergency operating procedures or the emergency plan) were trained and qualified in the use of self-contained breathing apparatuses (including personal bottle changeout). The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task.

The inspectors determined whether appropriate mask sizes and types are available for use (i.e., in-field mask size and type match what was used in fit-testing). The inspectors determined whether on-shift operators had no facial hair that would interfere with the sealing of the mask to the face and whether vision correction (e.g., glasses inserts or corrected lenses) was available as appropriate.

The inspectors reviewed the past two years of maintenance records for select self-contained breathing apparatus units used to support operator activities during accident conditions and designated as ready for service to assess whether any maintenance or repairs on any self-contained breathing apparatus units vital components were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. The vital components typically are the pressure-demand air regulator and the low-pressure alarm. The inspectors reviewed the onsite maintenance procedures governing vital component work to determine any inconsistencies with the self-contained breathing apparatus manufacturers recommended practices. For those self-contained breathing apparatuses designated as ready for service, the inspectors determined whether the required, periodic air cylinder hydrostatic testing was documented and up to date, and the retest air cylinder markings required by the U.S. Department of Transportation were in place.

b. Findings

No findings were identified.

.5 Problem Identification and Resolution (02.05)

a. Inspection Scope

The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by the licensee.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

Main article: IP 71124.04

These activities constituted one complete inspection sample as defined in IP 71124.04-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the results of the radiation protection program audits related to internal and external dosimetry (e.g., licensees quality assurance audits, self-assessments, or other independent audits) to gain insights into overall licensee performance in the area of dose assessment and focus the inspection activities consistent with the principle of smart sampling.

The inspectors reviewed the most recent national voluntary laboratory accreditation program accreditation report on the vendors most recent results to determine the status of the contractors accreditation.

A review was conducted of the licensee procedures associated with dosimetry operations, including issuance/use of external dosimetry (routine, multi-badging, extremity, neutron, etc.), assessment of internal dose (operation of whole-body counter, assignment of dose based on derived air concentration-hours, urinalysis, etc.), and evaluation of and dose assessment for radiological incidents (distributed contamination, hot particles, loss of dosimetry, etc.).

The inspectors evaluated whether the licensee had established procedural requirements for determining when external and internal dosimetry is required.

b. Findings

No findings were identified.

.2 External Dosimetry (02.02)

a. Inspection Scope

The inspectors evaluated whether the licensees dosimetry vendor is national voluntary laboratory accreditation program accredited and if the approved irradiation test categories for each type of personnel dosimeter used are consistent with the types and energies of the radiation present and the way the dosimeter is being used (e.g., to measure deep dose equivalent, shallow dose equivalent, or lens dose equivalent).

The inspectors evaluated the onsite storage of dosimeters before their issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to rad-workers with respect to care and storage of dosimeters.

The inspectors assessed whether non-national voluntary laboratory accreditation program accredited passive dosimeters (e.g., direct ion storage sight read dosimeters)were used according to licensee procedures that provide for periodic calibration, application of calibration factors, usage, reading (dose assessment) and zeroing. The licensee does not use non-national voluntary laboratory accreditation program accredited passive dosimeters.

The inspectors assessed the use of active dosimeters (electronic personal dosimeters)to determine if the licensee uses a correction factor to address the response of the electronic personal dosimeter as compared to the passive dosimeter for situations when the electronic personal dosimeter must be used to assign dose. The inspectors also assessed whether the correction factor is based on sound technical principles.

The inspectors reviewed dosimetry occurrence reports or CAP documents for adverse trends related to electronic personal dosimeters, such as interference from electromagnetic frequency, dropping or bumping, failure to hear alarms, etc. The inspectors assessed whether the licensee had identified any trends and implemented appropriate corrective actions.

b. Findings

No findings were identified.

.3 Internal Dosimetry (02.03)

a. Routine Bioassay (In Vivo)

(1) Inspection Scope The inspectors reviewed procedures used to assess the dose from internally deposited nuclides using whole-body counting equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, the route of intake and the assignment of dose.

The inspectors reviewed the whole-body count process to determine if the frequency of measurements was consistent with the biological half-life of the nuclides available for intake.

The inspectors reviewed the licensee's evaluation for use of its portal radiation monitors as a passive monitoring system to determine if instrument minimum detectable activities were adequate to determine the potential for internally deposited radionuclides sufficient to prompt additional investigation.

The inspectors selected several whole-body counts, and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors reviewed the radionuclide library used for the count system to determine its appropriateness. The inspectors evaluated whether any anomalous count peaks/nuclides indicated in each output spectra received appropriate disposition. The inspector's reviewed the licensee's 10 CFR Part 61 data analyses to determine whether the nuclide libraries included appropriate gamma-emitting nuclides. The inspectors evaluated how the licensee accounts for hard-to-detect nuclides in the dose assessment.