IR 05000373/2012003
| ML12207A558 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/25/2012 |
| From: | Michael Kunowski NRC/RGN-III/DRP/B5 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-12-003 | |
| Download: ML12207A558 (42) | |
Text
UNITED STATES uly 25, 2012
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT 05000373/2012003; 05000374/2012003
Dear Mr. Pacilio:
On June 30, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your LaSalle County Station, Units 1 and 2. The enclosed report documents the inspection results which were discussed on June 27, 2012, with the Site Vice President, Mr. D. Rhoades, 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.
One NRC-identified finding of very low safety significance (Green) was identified during this inspection.
This finding was determined to have not involved a violation of NRC requirements. Additionally, a licensee-identified violation is listed in Section 4OA7 of this report.
If you contest this finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the LaSalle County Station.
If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at LaSalle County Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Michael Kunowski, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-373 and 50-374 License Nos. NPF-11 and NPF-18
Enclosure:
Inspection Report 05000373/2012003; 05000374/2012003 w/Attachment: Supplemental Information
REGION III==
Docket Nos: 05000373; 05000374 License Nos: NPF-11; NPF-18 Report No: 05000373/2012003; 05000374/2012003 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: April 1, 2012 to June 30, 2012 Inspectors: Robert Ruiz, Senior Resident Inspector Frances Ramírez, Resident Inspector Mike Ziolkowski, Resident Inspector (Acting)
John Jandovitz, Project Engineer Tony Go, Health Physicist Kenya Carrington, Reactor Engineer Raymond Walton, Senior Operations Engineer Robert Schulz, Illinois Emergency Management Agency Approved by: Michael Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000373/2012003, 05000374/2012003; 04/01/2012 - 06/30/2012; LaSalle County Station,
Units 1 & 2; Surveillance Testing.
This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP); the cross-cutting aspects were determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after U.S. Nuclear Regulatory Commission (NRC) management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
A finding of very low safety significance was identified by the inspectors for the licensees failure to implement a station-required procedure step during surveillance testing of the standby gas treatment (SBGT) system. Specifically, the licensee failed to perform the step in LaSalle procedure LOS-VG-M1, Standby Gas Treatment System Operability and Inservice Test, which directs the SBGT manual initiation pushbuttons be tested every three years. Since the particular function of the pushbuttons is not required by regulation, and the procedure step was created only as a self-imposed station requirement, no violation of regulatory requirements occurred. Upon notification by the inspectors of the discrepancy, the licensee promptly entered the issue into its corrective action program (CAP) for evaluation and resolution.
The finding was determined to be more than minor because the performance deficiency of failing to meet procedure requirements, if left uncorrected, could have the potential to lead to a more significant safety concern. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Mitigating Systems Cornerstone, dated January 10, 2008. The finding was determined to be of very low safety significance because all questions in the Mitigating Systems column were answered No. This finding has a cross-cutting aspect in the area of human performance, work control, for failing to appropriately coordinate work activities and keep personnel apprised of work status. Specifically, because there was no predefine in the work management system, operators performing the surveillance test were not aware of the status of the triennial requirement (H.3(b)). (Section 1R22)
Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by inspectors. Corrective actions planned or taken by the licensee have been entered into the licensees CAP. This violation and CAP tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 The unit began the inspection period operating at full power. On May 26, 2012, power was reduced to approximately 50 percent for a control rod sequence exchange and scram time testing. Unit 1 was restored to full power later that day. Lastly, on June 29, power was reduced to approximately 92 percent due to an unplanned feedwater heater isolation caused by a weather-related 345-kilovolt grid disturbance. Unit 1 was restored to full power on June 30.
Unit 2 The unit began the inspection period operating at full power. On April 21, 2012, power was reduced to approximately 92 percent due to an unplanned feedwater controller failure. Unit 2 was restored to full power later that day. Lastly, on June 29, power was reduced to approximately 80 percent due to an unplanned feedwater heater isolation caused by a weather-related 345 kilovolt grid disturbance. Unit 2 was restored to full power on June
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify 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:
- the coordination between the TSO and the plant during off-normal or emergency events;
- the explanations for the events;
- the estimates of when the offsite power system would be returned to a normal state; and
- the 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:
- the 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;
- the 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;
- a 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
- the 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 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.
This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
.2 Summer Seasonal Readiness Preparations
a. Inspection Scope
The inspectors performed a review of the licensees preparations for summer weather for selected systems, including conditions that could lead to an extended drought.
During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions.
Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR)and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed 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. The inspectors review focused on a safety-related equipment walkdown after heavy rains.
This inspection constituted one seasonal adverse weather sample as defined in IP 71111.01-05.
b. Findings
No findings were identified.
.3 Readiness For Impending Adverse Weather Condition - Heavy Rainfall
a. Inspection Scope
The inspectors evaluated the design, material condition, and procedures for coping with adverse environmental conditions based on recent rainfall. The evaluation included a review to check for deviations from the descriptions provided in the UFSAR for features intended to mitigate the potential effects. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the diesel generator (DG) corridor roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate a heavy rainfall were in place and appeared functional. Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site which would inhibit site drainage during the heavy precipitation conditions or allow water ingress past a barrier.
This inspection constituted one readiness for impending adverse weather condition sample as defined in IP 71111.01-05
b. Findings
No findings were identified.
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 reactor core isolation cooling (RCIC) following work window;
- Unit 2 high pressure core spray while RCIC was inoperable; and
- Unit 1A DG during a hot weather alert.
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), assignment reports (ARs), 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 constituted three partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- 2J Unit 1 drywell;
- 2B1 Unit 1 reactor building, elevation 820 (on May 31, during static conditions);
- 3B1 Unit 2 reactor building, elevation 820; and
- 2B1 Unit 1 reactor building, elevation 820 (on June 22, during a period of heightened maintenance activity in the zone).
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.
Using the documents listed in the Attachment to this report, 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 four quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
.2 Annual Fire Protection Drill Observation
a. Inspection Scope
On June 22, 2012, the inspectors observed an unannounced fire brigade activation drill involving a simulated electrical fire in a 480 Volts Alternating Current (VAC) motor control center located in the Unit 1 turbine building basement elevation. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires.
The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions.
Specific attributes evaluated were:
- proper wearing of turnout gear and self-contained breathing apparatus;
- proper use and layout of fire hoses;
- employment of appropriate fire fighting techniques;
- sufficient firefighting equipment brought to the scene;
- effectiveness of fire brigade leader communications, command, and control;
- search for victims and propagation of the fire into other plant areas;
- smoke removal operations;
- utilization of pre-planned strategies;
- adherence to the pre-planned drill scenario; and
- drill objectives.
Documents reviewed are listed in the Attachment to this report.
These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding
.1 Internal Flooding
a. Inspection Scope
The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. Documents reviewed are listed in the Attachment to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees CAP documents with respect to past flood-related items identified in the CAP to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:
- Units 1 and 2 core standby cooling system pump rooms.
This inspection constituted one internal flooding sample as defined in IP 71111.06-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On May 29, 2012, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training 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 simulator sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
a. Inspection Scope
On June 28, 2012, the inspectors observed activities in the main control room during an extreme hot weather alert in conjunction with a heightened level of activity, i.e.,
numerous surveillance test activities that were deferred from earlier in the work week.
The combination of activities and environmental conditions required heightened awareness. 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 (if applicable);
- correct use and implementation of procedures;
- control board (or equipment) manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and emergency plan actions and notifications (if applicable).
The performance in these areas was compared to pre-established operator action expectations, procedural compliance, and task completion requirements.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.3 Conformance With Examination Security Requirements
a. Inspection Scope
The inspectors reviewed the facility licensees physical security controls (e.g., access restrictions and simulator I/O controls, simulator software) and integrity measures (e.g., security agreements, simulator software access) throughout the inspection period.
This activity was not a complete inspection and did not constitute a conformance with examination security requirements sample as defined in IP 71111.11B.
b. Findings
One licensee-identified finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) is documented in Section 4OA7 of this report. No other findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant system:
- Unit 1 main steam safety relief valves.
The inspectors 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 Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 65 (10 CFR 50.65), Appendix 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 /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 one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- Yellow risk on both units during Unit 1 SBGT work window in the April 9, 2012 work week;
- Yellow risk during Unit 2 Div III work window in the May 7 work week;
- Yellow risk during Unit 2 RCIC work window in the May 14 work week; and
- Yellow risk during Unit 1 standby liquid control (SBLC) system maintenance in the June 18 work week.
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.
Documents reviewed are listed in the Attachment to this report.
These maintenance risk assessments and emergent work control activities constituted three samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- RCIC underground leak monitoring (AR 1331412) for both units;
- missed testing requirement for SBGT manual initiation pushbuttons on both units;
- Unit 2 low pressure core spray (LPCS) and A residual heat removal (RHR) water leg pump;
- Unit 1 SBLC tank solution issue (AR 01187254);
- Unit 2 line 2DG06A minimum wall thickness issue (AR 00814658).
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 UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of CAP 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 seven samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modification:
- Unit 1 LPCS vibration dampener modification (permanent).
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening 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, as applicable, observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; the modification operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modification did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one permanent plant modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- Unit 1 RCIC following breaker inspections;
- unit common B VC after return fan suction damper limit switch issue;
- Unit 2 B DG;
- Unit 2 RCIC following planned work window;
- unit common B auxiliary electrical equipment room ventilation (VE) compressor breaker replacement; and
- Unit 1 LPCS vibration dampener modification.
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, 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 CAP documents associated with post-maintenance tests 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 six post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activity to determine whether the SBGT system was capable of performing its intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- LOS-VG-M1, SBGT System Operability and Inservice Test (Routine);
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the UFSAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one routine surveillance testing sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
Failure to Perform Surveillance Test Procedure Step
Introduction:
A finding of very low safety significance was identified by the inspectors for the licensees failure to implement a station required procedure step during surveillance testing of the SBGT system. Specifically, the licensee failed to perform the step in LaSalle procedure LOS-VG-M1, Standby Gas Treatment System Operability and Inservice Test, which directs the SBGT manual initiation pushbuttons be tested every three years.
Description:
While reviewing surveillance activities associated with LOS-VG-M1, the inspectors noted that step D.10 of the Limitations section stated Generic Letter 96-01 recommends starting both SBGTs by arming and depressing the U1(U2) SBGT MANUAL SYS TEST P/B (pushbutton) once every three years. The inspectors then noted that procedure step 2.2, which directed operators to use the pushbutton if required by step D.10, had been marked N/A (not-applicable). In order to verify that the surveillance tests were being performed in accordance with the procedural guidance, the inspectors requested the records showing the last time that step 2.2 had been performed. It was then discovered that step 2.2 had never been performed since its initial creation in 1996.
Since the manual initiation function of the SBGT system is not required by regulation due to the single failure criteria being satisfied by the auto-start capabilities of two redundant trains of SBGT, and since the procedure step was only created as a self-imposed station requirement in response to a recommendation from NRC Generic Letter 96-01, Testing of Safety-Related Logic Circuits, no violation of regulatory requirements occurred.
Upon notification by the inspectors of the discrepancy, the licensee promptly entered the issue into its CAP for evaluation and resolution. The licensee has since verified the functionality of the manual initiation pushbuttons.
Analysis:
The inspectors determined that the failure to perform a procedure step directing the testing of the SBGT manual initiation pushbutton once every three years was contrary to LOS-VG-M1 and was a performance deficiency.
The finding was determined to be more than minor because the performance deficiency of failing to meet procedural requirements, if left uncorrected, has the potential to lead to a more significant safety concern. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings, Table 4a, for the Mitigating Systems Cornerstone, dated January 10, 2008. The finding was determined to be of very low safety significance because all questions in the Mitigating Systems column were answered No.
This finding (FIN) has a cross-cutting aspect in the area of human performance, work control, for failing to appropriately coordinate work activities and keep personnel apprised of work status. Specifically, because there was no predefine (repetitive, routine work activity) in the work management system, operators performing the surveillance test were not aware of the status of the triennial requirement (H.3(b)).
Enforcement:
No violation of regulatory requirements occurred (FIN 05000373/2012003-01; 05000374/2012003-01, Failure to Perform Surveillance Test Procedure Step).
.2 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-RH-Q1 2A RHR service water pump operability and inservice testing (IST)
(Routine);
- LOS-DG-M1 0DG idle start (Routine);
- LIS-PC-114 drywell equipment drain sump (DWEDS) degraded condition, reactor coolant system (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 was in accordance with TSs, the UFSAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted two routine surveillance testing samples, one IST sample, and one RCS leak detection inspection sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on May 31, 2012, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the to this report.
This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.
b. Findings
No findings were identified.
.2 Training Observation
a. Inspection Scope
The inspector observed a simulator training evolution for licensed operators on May 31, 2012, 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 inspection of the licensees training evolution with emergency preparedness drill aspects constituted one sample as defined in IP 71114.06-05.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
This inspection constituted a partial sample as defined in IP 71124.06-5.
.1 Inspection Planning and Program Reviews (02.01)
Event Report and Effluent Report Reviews
a. Inspection Scope
The inspectors reviewed the radiological effluent release reports issued since the last inspection to determine if the reports were submitted as required by the Offsite Dose Calculation Manual (ODCM)/TSs. The inspectors reviewed anomalous results, unexpected trends, or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the CAP, and were adequately resolved.
The inspectors identified radioactive effluent monitor operability issues reported by the licensee as provided in effluent release reports, to review these issues during the onsite inspection, as warranted, given their relative significance and determine if the issues were entered into the CAP and adequately resolved.
b. Findings
No findings were identified.
.2 Offsite Dose Calculation Manual and Final Safety Analysis Report Review
a. Inspection Scope
The inspectors reviewed UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths so they could be evaluated during inspection walkdowns.
The inspectors reviewed changes to the ODCM made by the licensee since the last inspection against the guidance in NUREG-1302 and 0133, and Regulatory Guides (RGs) 1.109, 1.21, and 4.1. When differences were identified, the inspectors reviewed the technical basis or evaluations of the change during the onsite inspection to determine whether they were technically justified and maintain effluent releases as-low-as-is-reasonably-achievable.
The inspectors reviewed licensee documentation to determine if the licensee had identified any non-radioactive systems that had become contaminated as disclosed either through an event report or the ODCM since the last inspection. This review provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59 evaluations and allowed a determination if any newly contaminated systems had an unmonitored effluent discharge path to the environment, whether any required ODCM revisions were made to incorporate these new pathways and whether the associated effluents were reported in accordance with RG 1.21.
b. Findings
No findings were identified.
.3 Groundwater Protection Initiative Program
a. Inspection Scope
The inspectors reviewed reported groundwater monitoring results and changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.
b. Findings
No findings were identified.
.4 Procedures, Special Reports, and Other Documents
a. Inspection Scope
The inspectors reviewed Licensee Event Reports, event reports, and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.
The inspectors reviewed effluent program implementing procedures, particularly those associated with effluent sampling, effluent monitor setpoint determinations, and dose calculations.
The inspectors reviewed copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the licensees program and aid in selecting areas for inspection review (smart sampling).
b. Findings
No findings were identified.
.5 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down selected components of the gaseous and liquid discharge systems to evaluate whether equipment configuration and flow paths aligned with the documents reviewed in Section
.1 (02.01) above, and to assess equipment material
condition. Special attention was made to identify potential unmonitored release points (such as open roof vents in boiling water reactor turbine decks, temporary structures butted against turbine, auxiliary or containment buildings), building alterations that could impact airborne or liquid effluent controls, and ventilation system leakage that communicates directly with the environment.
For equipment or areas associated with the systems selected for review that were not readily accessible due to radiological conditions, the inspectors reviewed the licensee's material condition surveillance records, as applicable.
The inspectors walked down filtered ventilation systems to assess for conditions such as degraded high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system.
As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluent (including sample collection and analysis) to evaluate whether appropriate treatment equipment was used and the processing activities aligned with discharge permits.
The inspectors determined if the licensee had made significant changes to their effluent release points, e.g., changes subject to a 10 CFR 50.59 review or required NRC approval of alternate discharge points.
As available, the inspectors observed selected portions of the routine processing and discharge of liquid waste (including sample collection and analysis) to determine whether appropriate effluent treatment equipment was being used and that radioactive liquid waste was being processed and discharged in accordance with procedure requirements and aligns with discharge permits.
b. Findings
No findings were identified.
.6 Sampling and Analyses (02.03)
a. Inspection Scope
The inspectors selected effluent sampling activities, consistent with smart sampling, and assessed whether adequate controls had been implemented to ensure representative samples were obtained (e.g., provisions for sample line flushing, vessel recirculation, composite samplers, etc.).
The inspectors selected effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors to assess whether controls were in place to ensure compensatory sampling were performed consistent with the radiological effluent TS (RETS)/ODCM and that those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents.
The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.
The inspectors reviewed the results of the inter-laboratory comparison program to evaluate the quality of the radioactive effluent sample analyses and assessed whether the inter-laboratory comparison program included hard-to-detect isotopes as appropriate.
b. Findings
No findings were identified.
.7 Instrumentation and Equipment (02.04)
Effluent Flow Measuring Instruments
a. Inspection Scope
The inspectors reviewed the methodology the licensee used to determine the effluent stack and vent flow rates to determine if the flow rates were consistent with RETS/ODCM or UFSAR values, and that differences between assumed and actual stack and vent flow rates did not affect the results of the projected public doses.
b. Findings
No findings were identified.
Air Cleaning Systems
c. Inspection Scope
The inspectors assessed whether surveillance test results since the previous inspection for TS-required ventilation effluent discharge systems (high-efficiency particulate air and charcoal filtration), such as the SBGT system and the containment/auxiliary building ventilation system, met TS acceptance criteria.
d. Findings
No findings were identified.
.8 Dose Calculations (02.05)
a. Inspection Scope
The inspectors reviewed all significant changes in reported dose values compared to the previous Radiological Effluent Release Report (e.g., a factor of 5, or increases that approached Appendix I criteria) to evaluate the factors which may have resulted in the change.
The inspectors reviewed radioactive liquid and gaseous waste discharge permits to assess whether the projected doses to members of the public were accurate and based on representative samples of the discharge path.
The inspectors reviewed changes in the licensees offsite dose calculations since the last inspection to evaluate whether changes were consistent with the ODCM and RG 1.109. The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to evaluate whether appropriate factors were being used for public dose calculations.
The inspectors reviewed the latest Land Use Census to assess whether changes (e.g.,
significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of nearest member of the public or critical receptor, etc.) had been factored into the dose calculations.
For the releases reviewed above, the inspectors evaluated whether the calculated doses (monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I, and TS dose criteria.
b. Findings
No findings were identified.
.9 Groundwater Protection Initiative Implementation (02.06)
a. Inspection Scope
The inspectors reviewed monitoring results of the groundwater protection initiative to determine if the licensee had implemented its program as intended and to identify any anomalous results. For anomalous results or missed samples, the inspectors assessed whether the licensee had identified and addressed deficiencies through its CAP.
The inspectors reviewed identified leakage or spill events and entries made into 10 CFR 50.75(g) records. The inspectors reviewed evaluations of leaks or spills and reviewed any remediation actions taken for effectiveness. The inspectors reviewed onsite contamination events involving contamination of groundwater and assessed whether the source of the leak or spill was identified and mitigated.
For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by:
- assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and the radiological source term and assessed whether a survey/evaluation had been performed to include consideration of hard-to-detect radionuclides, and.
- determining whether the licensee completed offsite notifications, as provided in its groundwater protection initiative implementing procedures.
The inspectors reviewed the evaluation of discharges from onsite surface water bodies that contain or potentially contain radioactivity, and the potential for groundwater leakage from these onsite surface water bodies. The inspectors assessed whether the licensee was properly accounting for discharges from these surface water bodies as part of their effluent release reports.
The inspectors assessed whether onsite groundwater sample results and a description of any significant onsite leaks/spills into groundwater for each calendar year were documented in the Annual Radiological Environmental Operating Report for the radiological environmental monitoring program or the Annual Radiological Effluent Release Report for the RETS.
For significant, new effluent discharge points (such as significant or continuing leakage to groundwater that continues to impact the environment if not remediated), the inspectors evaluated whether the ODCM was updated to include the new release points.
b. Findings
No findings were identified.
.10 Problem Identification and Resolution (02.07)
a. Inspection Scope
Inspectors assessed whether problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. In addition, they evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, and Occupational Radiation Safety
4OA1 Performance Indicator Verification
.1 Reactor Coolant System Leakage
a. Inspection Scope
The inspectors sampled licensee submittals for the RCS Leakage PI for Units 1 and 2 for the second quarter 2011 through the first quarter 2012. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, were used. The inspectors reviewed the licensees operator logs, RCS leakage tracking data, ARs, event reports, and NRC Integrated Inspection Reports for the period to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP 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 were identified.
.2 RETS/ODCM Radiological Effluent Occurrences
a. Inspection Scope
The inspectors sampled licensee submittals for the RETS/ODCM Radiological Effluent Occurrences PI for the first quarter 2011 through the first quarter 2012. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees CAP database and selected individual ARs 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 to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the to this report.
This inspection constituted one RETS/ODCM radiological effluent occurrences sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline IPs 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: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for followup, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily AR packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
.3 Semiannual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the six-month period of January 1 through June 30, 2012, although it was mostly focused during the time of L1R14, the recent Unit 1 refueling outage.
This review constituted a single semiannual trend inspection sample as defined in IP 71152-05.
b. Findings and Observations
The inspectors trend review focused on the ARs generated during the February/March 2012 refueling outage, L1R14. Specifically, the inspectors focused on ARs that could call into question the past operability of safety-related equipment and, as a result, expose a missed licensee event report. Given that during a refueling outage a number of the safety-related components are not required by TSs, the inspectors paid particular attention to the operability determination of each issue to ensure that the licensee had considered any reportability aspects that could result from a failed surveillance test. For example, if a safety-related piece of equipment failed a surveillance test during the outage, the majority of instances the operability determination would state that, in the shutdown mode, the equipment was not needed and that there was presently no operability concern. The NRCs NUREG-1022 Event Reporting Guidelines 10 CFR 50.72 and 50.73, states in part, that for the purpose of evaluating the reportability of a discrepancy found during surveillance testing that is required by TSs, it should be assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information such as equipment history and the cause of failure, to indicate that the discrepancy existed previously. As a result, in addition to evaluating present operability, the licensee was expected to assess equipment history and verify that the operability of the equipment was not challenged before the time of discovery.
The inspectors noticed a general lack of robust documentation and consistency in the licensees assessment of the reportability of issues identified during the outage. The licensee relied heavily on the unit being shut down to justify the operability determination and that reportability need not be assessed. Although the inspectors identified no violations of regulatory requirements, additional attention to this area by the licensee was warranted.
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On June 27, 2012, the inspectors presented the inspection results to Mr. D. Rhoades, 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 inspection results for the areas of radioactive gaseous and liquid effluent treatment; and RETS/ODCM radiological effluent occurrences PI verification with Mr. D. Rhoades, Site Vice President, on May 11, 2012, and
- the inspection results for the licensed operator examination security issue with Mr. D. Rhoades, Site Vice President, and other members of the licensee staff on July 12, 2012.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV:
- 10 CFR 55.49, Integrity of Examinations and Tests, requires, in part, that the licensee shall not engage in activities that compromise the integrity of any application, test, or examination required by 10 CFR Part 55. Contrary to the above, on March 30, 2012, at the Clinton Power Station, the licensee identified that the control room simulators plant process computer model was saving sequence of events files on a routine basis. A licensee investigation determined that the same condition existed at other Midwest Exelon sites, including the LaSalle County Station. The licensee determined that some of the files contained examination materials related to examinations required by 10 CFR Part 55. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Although the examination materials were available for scrutiny by unauthorized personnel (compromised), the licensee was able to demonstrate that the files were not readily viewable, required interpretation and additional administrative controls were in place that would likely inhibit access to, and reconstruction of simulator events. The inspectors determined that no individuals had an unfair advantage in taking any NRC-related examinations. This issue was documented in the facilitys CAP as AR1350492. Corrective actions for this issue included revising Simulator Security Checklist, TQ-LA-201-0113, to manually delete data from the sequence of events files during reset of the simulator.
The inspectors determined that the failure to control sequence of event files generated by the facilitys simulator was a performance deficiency affecting examination integrity that required a SDP evaluation. The inspectors determined that this finding impacted the Mitigating Systems Cornerstone and consulted IMC 0609, Appendix I, to assess the impact of this issue on examination security.
The inspectors concluded that an examination compromise had occurred; however, no actual effect on the equitable administration of an examination was identified. Also, the facility had taken immediate compensatory actions to prevent recurrence of this condition. Based on circumstances described above and the licensees corrective actions, the inspectors concluded that this finding was of very low safety significance and dispositioned it as a Green NCV.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Rhoades, Site Vice President
- P. Karaba, Plant Manager
- C. Howard, Manager, Radiation Protection Operation
- R. Conley, Manager, Technical Support
- T. Hapak, Chemistry
- K. Hedgspeth, Radiation Protection Manager
- J. Houston, Nuclear Oversight Manager
- T. Simpkin, Regulatory Affairs Manager
- H. Vinyard, Site Engineering Director
- M. Sharma, Engineering Program Manager
- S. Shields, Regulatory Affairs
- J. Smith, Operations Training Manager
- J. Hughes, Emergency Preparedness Coordinator
Nuclear Regulatory Commission
Michael Kunowski, Chief, Reactor Projects Branch 5
Billy Dickson, Chief, Plant Support Team
Hironori Peterson, Chief, Operations Branch
Attachment
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000373/2012003-01; FIN Failure to Perform Surveillance Test Procedure Step
- 05000374/2012003-01 (Section 1R22)
Closed
- 05000373/2012003-01; FIN Failure to Perform Surveillance Test Procedure Step
- 05000374/2012003-01 (Section 1R22)
Attachment