IR 05000373/2008004
| ML083100251 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/04/2008 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
| To: | Pardee C AmerGen Energy Co, Exelon Nuclear |
| References | |
| IR-08-004 | |
| Download: ML083100251 (46) | |
Text
ber 4, 2008
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT 05000373/2008004; 05000374/2008004
Dear Mr. Pardee:
On September 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your LaSalle County Station, Units 1 and 2. The enclosed report documents the results of this inspection, which were discussed on October 2, 2008, with Site Vice President, Mr. Daniel Enright, 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 NRC-identified or self-revealed findings of safety significance were identified. There were no findings involving a violation of NRC requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18 Enclosure: Inspection Report 05000373/2008004; 05000374/2008004 w/Attachment: Supplemental Information cc w/encl: Site Vice President - LaSalle County Station Plant Manager - LaSalle County Station Regulatory Assurance Manager - LaSalle County Station Chief Operating Officer and Senior Vice President Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Braidwood, Byron and LaSalle Associate General Counsel Document Control Desk - Licensing Assistant Attorney General J. Klinger, State Liaison Officer, Illinois Emergency Management Agency Chairman, Illinois Commerce Commission
SUMMARY OF FINDINGS
IR 05000373/2008004, 05000374/2008004; 7/01/2008 - 9/30/2008; LaSalle County Station,
Units 1 & 2; routine integrated report.
The inspection was conducted by U.S. Nuclear Regulatory Commission (NRC) resident inspectors and regional inspectors. The report covers a three-month period of resident inspection, and announced inspection in the areas of health physics, heat sink performance, and diesel generator performance testing. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Inspector-Identified and Self-Revealed Findings No findings of significance were identified.
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
Summary of Plant Status
Unit 1 The unit began the inspection period operating at full power. On July 20, 2008, the unit was reduced to 82 percent for motor driven reactor feed pump and main turbine valve surveillance testing. The unit returned to full power that same day. On September 6, 2008, power was reduced to approximately 66 percent to perform control rod sequence exchange and scram time testing. Operation at full power resumed on September 7, 2008. On September 28, 2008, the unit was shutdown to perform repairs of a hydrogen leak on the main generator housing. The unit remained in mode 3 (hot shutdown) for the rest of the inspection period.
Unit 2 The unit began the inspection period operating at full power. On July 27, 2008, power was reduced to approximately 62 percent for channel distortion testing of all the interior rods. The unit was returned to full power that same day. On August 30, 2008, the unit commenced a reduction in power to 53 percent for control rod sequence exchange and feedwater pump turbine surveillances. The unit was returned to full power on August 31, 2008, where it remained until September 26, 2008. At this time, power was reduced to 55 percent for power suppression testing, control rod SCRAM time testing and channel distortion testing. Full power was restored on September 29, 2008, and the unit remained operating at or near full power for the rest 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:
- Unit 2 low pressure core spray (LPCS);
- 2A standby liquid control (SLC) with 2B out-of-service; and
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), Technical Specification (TS) requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify 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 corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the Attachment.
These activities constituted three partial system walkdown samples as defined in Inspection Procedure (IP) 71111.04-05.
b. Findings
No findings of significance were identified.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
On August 27 through August 29, 2008, the inspectors performed a complete system alignment inspection of the fire protection system to verify the functional capability of the system. This system was selected because it was considered risk-significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders (WOs)was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved.
Documents reviewed are listed in the Attachment to this report.
These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- Fire Zone 7B3 0 DG Room;
- Fire Zone 4F2 Unit 2 Division 1 switchgear;
- Fire Zone 2G Unit 1 reactor building 710;
- Fire Zone 214 Unit 1 reactor core isolation cooling (RCIC)/LPCS; and
- Fire Zone 2B1 Unit 1 reactor building 820.
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 had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified 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 inspection samples as defined in IP 71111.05-05.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
.1 Triennial Review of Heat Sink Performance
a. Inspection Scope
The inspectors reviewed operability determinations, completed surveillances, vendor manual information, associated calculations, performance test results and cooler inspection results associated with the 2B Residual Heat Removal (RHR) heat exchanger and the DG common to both units (0 DG) heat exchanger. These heat exchangers were chosen based on their risk significance in the licensees probabilistic safety analysis, their important safety-related mitigating system support functions and their relatively low margin.
For the 2B RHR and the 0 DG heat exchangers, the inspectors verified that testing, inspection, maintenance, and monitoring of biotic fouling and macrofouling programs were adequate to ensure proper heat transfer. This was accomplished by verifying the test method used was consistent with accepted industry practices, or equivalent, the test conditions were consistent with the selected methodology, the test acceptance criteria were consistent with the design basis values, and results of heat exchanger performance testing. The inspectors also verified that the test results appropriately considered differences between testing conditions and design conditions, the frequency of testing based on trending of test results was sufficient to detect degradation prior to loss of heat removal capabilities below design basis values and test results considered test instrument inaccuracies and differences.
For the 2B RHR and the 0 DG heat exchanger, the inspectors reviewed the methods and results of heat exchanger performance inspections. The inspectors verified the methods used to inspect and clean heat exchangers were consistent with as-found conditions identified and expected degradation trends and industry standards, the licensees inspection and cleaning activities had established acceptance criteria consistent with industry standards, and the as-found results were recorded, evaluated, and appropriately dispositioned such that the as-left condition was acceptable.
The inspectors verified the performance of the ultimate heat sink (UHS) and their subcomponents, including piping, intake screens, pumps, and valves, by tests or visual inspection to ensure availability and accessibility to the in-plant cooling water systems.
The inspectors reviewed the results of the licensees inspection of the UHS weirs or excavations. The inspectors verified that identified settlement or movement indicating loss of structural integrity and/or capacity was appropriately evaluated and dispositioned by the licensee. In addition, the inspectors verified the licensee ensured sufficient reservoir capacity by trending and removing debris or sediment buildup in the UHS.
The inspectors performed a system walkdown of the service water intake structure to verify the licensees assessment on structural integrity and component functionality.
This included the verification that licensee ensured proper functioning of traveling screens and strainers, and structural integrity of component mounts. In addition, the inspectors verified that service water pump bay silt accumulation is monitored, trended, and maintained at an acceptable level by the licensee, and that water level instruments are functional and routinely monitored. The inspectors also verified the licensees ability to ensure functionality during adverse weather conditions.
In addition, the inspectors reviewed condition reports related to the heat exchangers/coolers and heat sink performance issues to verify that the licensee had an appropriate threshold for identifying issues and to evaluate the effectiveness of the corrective actions. The documents reviewed are included in the Attachment to this report.
These inspection activities constituted two heat sink inspection samples as defined in IP 71111.07-05.
b. Findings
No findings of significance were identified
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review
a. Inspection Scope
On September 16, 2008, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk significant systems/components:
- Maintenance rule functional failure assessment for control rod drive (CRD)pressure control bypass valve 1C11-F004.
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 licensees 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 the Code of Federal Regulations (CFR)10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensees 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:
- Unit 1 motor-driven reactor feed pump protected pathway;
- Unit 2 electro-hydraulic control (EHC) filter emergent replacement;
- 2B non-essential service water jockey pump suction pipe thru-wall flaw; and
- 1B DG protected pathway.
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 licensees probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- Division 3 125VDC battery testing procedural adequacy;
- Unit 1 under vessel high temperature conditions;
- Generic Letter 08-01 emergency core cooling system gas entrainment assessment;
- 1C low pressure coolant injection (LPCI) suction valve thermal overload setpoint adjustment; and
- Core standby cooling system (CSCS) operability following hypothesized internal flooding with actual high cooling lake levels (greater than 701 elevation).
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 Updated Safety Analysis Report (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 determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also 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.
This operability inspection constituted five samples as defined in IP 71111.15-05
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed the containment ventilation (VP) chiller compressor trip bypass feature modification. They compared the temporary configuration changes and associated 10 CFR 50.59 screening and evaluation information against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors also compared the licensees information to operating experience information to ensure that lessons learned from other utilities had been incorporated into the licensees decision to implement the temporary modification. Lastly, the inspectors discussed the temporary modification with operations and engineering personnel to ensure that the individuals were aware of how extended operation with the temporary modification in place could impact overall plant performance. This temporary modification was approved for installation but had not yet been installed by the licensee by the close of this inspection period.
This inspection constituted one temporary modification sample as defined in IP 71111.18-05.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing (PMT)
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following PMT activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- Drywell equipment drain sump outlet valve testing after emergent maintenance;
- 2B DG starting air compressor discharge check valve testing;
- 1C LPCI motor operated valve strokes following planned electrical breaker maintenance;
- 1B residual heat removal (RH) pump and valve run and strokes following planned electrical breaker maintenance; and
- 0 DG emergency fast start following a planned upkeep window.
These activities were selected based upon the structure, system, or components ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion), and test documentation was properly evaluated. The inspectors evaluated the activities against TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure 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 PMT 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.
This inspection constituted five PMT samples as defined in IP 71111.19-05.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- LOS-R1-Q5; RCIC cold quick start (Routine);
- LOS-SQ-Q1 2B SLC pump and valve quarterly (Routine);
- LOS-VC-SR1 Control room and auxiliary electric equipment room ventilation pressurization surveillance (Routine);
- Unit 1 and Unit 2 drywell equipment drains (identified leakage) and drywell floor drains (unidentified leakage) surveillances (RCS).
The inspectors observed in plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency were in accordance with TSs, the USAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted three routine surveillance testing samples, one inservice testing sample, and one reactor coolant system leak detection inspection sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation
.1 Training Observation
a. Inspection Scope
The inspector observed a simulator training evolution for licensed operators on September 16, 2008, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator (PI) data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew.
The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the CAP. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.
This training inspection constituted one sample as defined in IP 71114.06-05.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
.1 Plant Walkdowns and Radiation Work Permit (RWP) Reviews
a. Inspection Scope
The inspectors assessed the adequacy of the licensees internal dose assessment process for internal exposures in excess of 50 millirem committed effective dose equivalent. The inspectors also reviewed the licensees physical and programmatic controls for highly activated and/or contaminated materials (non-fuel) stored within the spent fuel pool or other storage pools.
This occupational radiation safety plant walkdown and RWP review constituted two samples as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified.
.2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed licensee documentation packages for all PI events occurring since the last inspection to determine if any of these PI events involved dose rates greater than 25 R/hr at 30 centimeters or in excess of 500 R/hr at 1 meter. Barriers were evaluated for failure and to determine if there were any barriers left to prevent personnel access. Unintended exposures exceeding 100 millirem total effective dose equivalent (or 5 Rem shallow dose equivalent or 1.5 Rem lens dose equivalent) were evaluated to determine if there were any regulatory overexposures or if there was a substantial potential for an overexposure.
This radiation safety licensee documentation inspection constituted one sample as defined in IP 71121.01-5.
b. Findings
No findings of significance were identified.
2OS2 As-Low-As-Is-Reasonably-Achievable (ALARA) Planning and Controls (71121.02)
.1 Declared Pregnant Workers
a. Inspection Scope
The inspectors reviewed dose records of declared pregnant workers for the current assessment period to verify that the exposure results and monitoring controls employed by the licensee complied with the requirements of 10 CFR Part 20. The inspectors reviewed the licensees program for declared pregnant workers. The inspectors evaluated if that program complied with the requirements of 10 CFR Part 20.
This ALARA declared pregnant workers inspection constituted one required sample as defined in IP 71121.02-5.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours PI for Unit 1 and Unit 2 for the period from the 4th quarter 2007 through the 2nd quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5 were used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports and NRC Inspection Reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted two unplanned scrams per 7000 critical hours samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.2 Unplanned Scrams with Complications
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams with Complications PI for Unit 1 and Unit 2 for the period from the 4th quarter 2007 through the 2nd quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports and NRC Integrated Inspection Reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two unplanned scrams with complications samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.3 Unplanned Transients per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours PI for Unit 1 and Unit 2 for the period from the 4th quarter 2007 through the 2nd quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, maintenance rule records, event reports and NRC Integrated Inspection Reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two unplanned transients per 7000 critical hours samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.4 Reactor Coolant System (RCS) Specific Activity
a. Inspection Scope
The inspectors sampled licensee submittals for the RCS Specific Activity PI for Unit 1 and Unit 2 for the period from the 4th quarter 2007 through the 2nd quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees RCS chemistry samples, TS requirements, issue reports, and event reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals.
The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator, and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two RCS specific activity samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.5 Reactor Coolant System Leakage
a. Inspection Scope
The inspectors sampled licensee submittals for the RCS Leakage PI for Unit 1 and Unit 2 for the period from the 4th quarter 2007 through the 2nd quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees operator logs, RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection Reports for the period of October 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two RCS leakage samples as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.6 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors sampled licensee submittals for the Occupational Radiological Occurrences PI for the period from the 3rd quarter 2007 through the 2nd quarter 2008.
To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine if indicator related data was adequately assessed and reported. To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with radiation protection staff, the scope and breadth of its data review, and the results of those reviews. The inspectors independently reviewed electronic dosimetry dose rate and accumulated dose alarm and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one occupational radiological occurrences sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
.7 Radiological Effluent TS/Offsite Dose Calculation Manual Radiological Effluent
Occurrences
a. Inspection Scope
The inspectors sampled licensee submittals for the Radiological Effluent TS (RETS)/Offsite Dose Calculation Manual (ODCM) Radiological Effluent Occurrences PI for the period from the 3rd quarter 2007 through the 2nd quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees issue report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates between from the third quarter 2007 through the second quarter 2008, to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Additionally, the inspectors reviewed the licensees historical 10 CFR 50.75(g) file and selectively reviewed the licensees analysis for discharge pathways resulting from a spill, leak, or unexpected liquid discharge focusing on those incidents which occurred over the last few years. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one RETS/ODCM radiological effluent occurrences sample as defined in IP 71151-05.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
.1 Routine Review of items Entered Into the CAP
a. Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and that previous occurrences reviews were proper and adequate. Also, the classification, prioritization, focus, and timeliness of corrective actions were reviewed to ensure they were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the attached list of documents reviewed.
These routine reviews from IP 71152 for the identification and resolution of problems did not constitute any additional inspection samples. Instead, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings of significance were identified.
.2 Daily CAP Reviews
a. Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed as defined in IP 71152 as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings of significance were identified.
.3 Annual Review: Operator Workarounds (OWA)
a. Scope
The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the OWAs on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.
The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment were reviewed to accomplish the objectives of the inspection procedure. The inspectors also reviewed operator challenges, which create an obstacle to normal plant operation, rather than the more severe obstacle to safe plant operation created by an OWA. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP and proposed or implemented appropriate and timely corrective actions which addressed each issue.
Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds. In addition, interviews were conducted with equipment operators and licensed control room operators to determine if longstanding workarounds existed and had in turn been proceduralized into a part of accepted practice.
This operator workarounds annual inspection review constituted one sample as defined in IP 71152.
b. Findings
No findings of significance were identified.
.4 Annual Review: Safety-Related Procedure Changes
a. Scope
The inspectors reviewed a sample of approximately 100 issue reports associated with revisions to plant procedures that were associated with safety-related components or emergency operations to evaluate whether the licensees process to identify, prioritize and resolve changes needed for those procedures was adequate. Specifically, the inspectors selected procedural changes for which the due dates were moved by more than six months and revisions that would directly impact Emergency Operating Procedures. The inspectors evaluated the validity of extending the due date on a needed revision of a safety-related procedure and ensured the revisions were timely and commensurate with the safety significance of the issue. Additionally, the inspectors verified that established corrective actions by the licensee for the safety-related procedures were appropriately focused to correct the problem.
b. Observations The inspectors noted that the licensee properly identified deficiencies in their procedures; however, the process for prioritizing and resolving the changes lacked some organization. Specifically, it was the responsibility of a few individuals from the Operations and Training departments to ensure that these procedure revisions were performed in a timely manner. The inspectors noticed that there was not a formal threshold or process to establish priorities for procedures needing modification other than personal discretion and foreseen or unforeseen events. Some examples of events that influenced the establishment of due dates were refueling outages, major equipment malfunctions and other NRC inspections.
The inspectors observed that the events that influenced the priority category and original due dates for the issue reports were also used as basis for adjusting the due dates when the actions required could not be completed in time. Additionally, the inspectors noted that in most of the issue reports with postponements, no written justification was provided for deferring the completion date. The inspectors interviewed the personnel in charge of these procedure changes to gather the information on each issue and assess whether the delays were handled in accordance with safety significance. From the sample selected, approximately 20 percent of the procedure changes required were deferred from the original due dates several times and in some cases they were pushed back by more than 6 months up to a year.
The inspectors concluded that the licensee identified necessary procedural changes commensurate with safety. However, due to the workload of personnel tasked with these changes, the prioritization and execution of these procedural revisions could improve by performing a more structured significance determination and by justifying due date rescheduling to better track the program. The inspectors did not identify any issues where the resolution timeliness of the issue report compromised the safety of plant operation.
This safety related procedural changes review constituted one inspection sample as defined in IP 71152.
c. Findings
No findings of significance were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) LER 05000374/2008001-00, High Pressure Core Spray System Declared
Inoperable Due to Failed Room Ventilation Supply Fan
a. Inspection Scope
On June 11, 2008, the supply fan for the Division 3 switchgear room ventilation system (VD) tripped unexpectedly. Division 3 switchgear supports the high pressure core spray (HPCS) system. High pressure core spray remained available to inject into the reactor vessel if needed, but was declared inoperable due to potential room heat-up with the rooms ventilation failed. As HPCS is a single train system, this failure resulted in a complete loss of system function, requiring the licensee to make an eight hour notification to the NRC under 10 CFR 50.72(b)(3)(v)(D). This event was also classified as a Safety System Functional Failure. The failure mechanism was identified by the licensee as a phase to ground short on the fans motor winding. The licensee determined the apparent cause of the motor winding failure to be a lack of a time-based refurbishment/replacement program for high duty cycle (continuously run) motors. The motor in question received periodic greasing of its bearings and quarterly vibration analysis, but no refurbishment/ replacement schedule had been established. This component was from original construction (approximately 25 years old) and vendor environmental qualification records analyzed that this component was expected to last for the licensed lifetime of the plant (40 years).
During the apparent cause investigation, the licensee identified Electric Power Research Institute (EPRI) guidance that revealed that high duty cycle motors in low power applications, such as ventilation fans, have been known to show signs of electrical degradation beginning at approximately 20 years of service. As a corrective action, the licensee established a 20 year refurbishment/replacement criteria for the supply fan in question. The licensee performed an extent of condition review of all 480 volt motors site wide extending the 20 year criterion to all critical (safety/risk significant), high duty cycle, single train, and short duration TS shutdown time clock (less than or equal to seven days) motor driven components. This expanded the motor population to four total components (the supply and return fans associated with each units Division 3 VD system). The inspectors review of the EPRI operating experience showed it to be general in nature, lacking the specificity that would reasonably cause the licensee to reevaluate previous vendor lifetime qualification data and as such the failure to establish a refurbishment/replacement criteria based on industry experience was not considered a performance deficiency. Documents reviewed in this inspection are listed in the
. This LER is closed.
This event follow-up review constituted one sample as defined in Inspection Procedure 71153-05.
b. Findings
No findings of significance were identified.
4OA5 Other
Cornerstone: Physical Protection
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
The inspectors also reviewed a report of the results of a survey of the site security organization relative to its safety conscious work environment. The inspectors considered whether the surveys were conducted in a manner that encouraged candid and honest feedback. The results were reviewed to determine whether adequate number of staff responded to the survey. The inspectors also reviewed Exelons self-assessment of the survey results and verified that any issues or areas for improvement were entered into the CAP for resolution.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 2, 2008, the inspectors presented the inspection results to Site Vice President, Mr. Daniel Enright, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The results of the heat sink performance inspection with the Plant Manager, Mr. D. Rhoades, on July 25, 2008; and
- The results of the radiation protection inspection with the Plant Manager, Mr. D. Rhodes, on August 29, 2008.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
4OA7 Licensee-Identified Violations
None.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Enright, Site Vice President
- D. Rhoades, Plant Manager
- J. Bashor, Site Engineering Director
- L. Blunk, Operations Training Manager
- S. Wilkinson, Chemistry Manager
- H. Do, Corporate Inservice Inspection Manager
- B. Ginter, Engineering Programs Manager
- F. Gogliotti, System Engineering Senior Manager
- W. Hilton, Engineering Supervisor - Mechanical/Structural
- K. Ihnen, Nuclear Oversight Manager
- A. Kochis, Inservice Inspection Engineer
- R. Leasure, Radiation Protection Manager
- S. Marik, Operations Director
- B. Rash, Maintenance Director
- J. Rommel, Design Engineering Senior Manager
- K. Rusley, Emergency Preparedness Manager
- J. Shields, Inservice Inspection Program Supervisor
- T. Simpkin, Regulatory Assurance Manager
- H. Vinyard, Shift Operations Superintendent
- G. Wilhelmsen, Design Manager
- J. White, Site Training Director
- C. Wilson, Station Security Manager
- D. Amezaga, GL 89-13 Program Owner
- J.C. Feeney, NOS Lead Assessor
- D. Henly, Design Engineer
Nuclear Regulatory Commission
- K. Riemer, Chief, Reactor Projects Branch 2
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None.
Closed
- 05000374/2008001-00 LER High Pressure Core Spray System Declared Inoperable Due to Failed Room Ventilation Supply Fan (4OA3)
Discussed
None.
Attachment