IR 05000373/2015003
| ML15316A067 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/10/2015 |
| From: | Michael Kunowski NRC/RGN-III/DRP/B5 |
| To: | Bryan Hanson Exelon Generation Co |
| References | |
| IR 2015001, IR 2015003 | |
| Download: ML15316A067 (56) | |
Text
UNITED STATES ber 10, 2015
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT AND NOTICE OF DEVIATION 05000373/2015003; 05000374/2015003; 07200070/2015001
Dear Mr. Hanson:
On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your LaSalle County Station, Units 1 and 2. On October 6, 2015, the NRC inspectors discussed the results of this inspection with Mr. P. Karaba and other members of your staff. The results of this inspection are documented in the enclosure.
No NRC-identified or self-revealing findings were identified during this inspection; however, deviations from commitments associated with your license were identified. In accordance with the NRC Enforcement Policy, the deviations are described in the enclosed Notice of Deviation (Notice).
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements and commitments. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Michael Kunowski, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-373, 50-374, and 72-070 License Nos. NPF-11 and NPF-18
Enclosure:
Inspection Report 05000373/2015003; 05000374/2015003; 07200070/2015001 w/Attachments: Supplemental Information and Notice of Deviation
REGION III==
Docket Nos: 05000373; 05000374; 07200070 License Nos: NPF-11; NPF-18 Report Nos: 05000373/2015003; 05000374/2015003; 07200070/2015001 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: July 1 through September 30, 2015 Inspectors: R. Ruiz, Senior Resident Inspector J. Robbins, Resident Inspector M. Learn, Acting Resident Inspector and MCID/DNMS J. Cassidy, RIII Senior Health Physicist V. Myers, RIII Senior Health Physicist S. Winters, RIII Observer R. Zuffa, Illinois Emergency Management Agency, Resident Inspector Approved by: M. Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report 05000373/2015003, 05000374/2015003, 07200070/2015001; 07/01/2015 - 09/30/2015; LaSalle County Station, Units 1 and 2; Routine Integrated Inspection Report This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, effective date December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
REPORT DETAILS
Summary of Plant Status
Unit 1 The unit began the inspection period operating at full power. On September 12, 2015, power was reduced to approximately 70 percent for a control rod sequence exchange and scram time testing. Unit 1 was restored to full power the next day.
Unit 2 The unit began the inspection period at approximately 90 percent power to stabilize elevated vibrations on the turbine-driven reactor feedwater system. Full power was restored on July 4, 2015. On August 6, the unit began shutting down for maintenance outage L2M18, to perform repairs on degraded components in the reactor recirculation and feedwater systems.
After completion of the outage, power ascension began on August 15, with full power achieved on August 19. On September 5, power was reduced to approximately 60 percent for routine surveillances as well as to perform power suppression testing to identify the physical location of a previously identified fuel leak. Once the leak was identified and suppressed, full power was achieved on September
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R01 Adverse Weather Protection
.1 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. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into the CAP in accordance with station CAP procedures. The inspectors reviews focused specifically on the following plant systems: the screenhouse, and Units 1 and 2 transformers.
This inspection constituted one seasonal adverse weather sample as defined in Inspection Procedure (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 1 low pressure core spray (LPCS);
- Unit 1 reactor core isolation cooling (RCIC);
- Unit 2 LPCS;
- Unit 2 RCIC; and
- Unit 1, Train A standby liquid control system.
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), 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 CAP with the appropriate significance characterization. Documents reviewed are listed in the to this report.
These activities constituted five 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:
- Fire Zone (FZ) 7C1-7C6 Unit 1, Division I-III diesel fuel tank rooms and Division I and II residual heat removal (RHR) service water pump rooms;
- FZ 4E3 Unit 1, Division II essential switch gear;
- FZ 4F2 Unit 2, Division I essential switch gear room;
- FZ 8C1-8C5 Unit 2, Division I-II RHR service water pump and diesel fuel tank rooms; and
- FZ 8B1 Unit 2 high pressure core spray (HPCS) diesel generator (DG) room.
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.
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 five 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 August 25, 2015, the inspectors observed a fire brigade activation for an unannounced drill. 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 firefighting 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.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On July 13, 2015, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that 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 71111.11-05.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk
(71111.11Q)
a. Inspection Scope
On September 5, 2015, the inspectors observed Unit 2 power suppression testing during activities performed to locate a leaking fuel assembly. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms (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 71111.11-05.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- continuous operation of 3 reactor feedwater pumps; and
- seismic monitoring system computer.
The inspectors reviewed events, such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems, and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
.2 (Closed) Unresolved ItemBoth Ammonia Detectors Non-Functional on Unit 0 Train A
of Control Room Ventilation
Introduction:
As previously documented in Inspection Report 05000373/2015002; 05000374/2015002, the inspectors identified an unresolved item (URI) concerning the failure of both Unit-common Train A (0A) control room ventilation ammonia detectors.
These detectors were previously removed from the TSs by amendment.
Description:
On June 26, licensee staff identified that both ammonia detectors in the 0A Train of control room ventilation were non-functional. The inspectors identified that Amendments 61 and 42 (to the Unit 1 and Unit 2 operating licenses) were approved by the NRC on January 18, 1989, and contained a number of commitments regarding these detectors, including a commitment specific to the alarm capability of the detectors.
Further review by the inspectors and the licensee identified that these commitments, however, were not included in the licensees current list of regulatory commitments. The commitments for the detectors predated the implementation of the licensees formal commitment tracking program. This issue has been entered into the CAP as AR 02520223, NRC Question on Ammonia Detector Commitment.
Analysis:
Amendments 61 and 42 approved the removal of ammonia detectors from TSs. As part of the approval, licensee commitments in referenced letters from C. Allen, Commonwealth Edison (the original licensee for LaSalle) to the NRC dated March 6, 1987, supplemented January 6 and March 9, 1988, and on January 6, 1989, were incorporated. In addition to the commitment for leaving the alarm function of the ammonia detectors in place, the licensee had committed to pursue agreements with offsite agencies to notify LaSalle in the event of a major anhydrous ammonia release offsite that could affect LaSalle and to prohibit the use of anhydrous ammonia on property near LaSalle that the licensee leased to other entities. The inspectors identified the failure of the licensee to meet these three commitments as Deviations. These Deviations have been documented in the attached Notice of Deviation, in accordance with the NRC Enforcement Policy, dated February 4, 2015.
This URI is considered closed.
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:
- shutdown maintenance risk evaluation, planned maintenance affecting HPCS;
- Unit 1 during elevated risk, undervoltage relay calibration;
- Unit 2 during elevated risk, undervoltage relay calibration; and
- dry cask storage during elevated risk, placing cask in pool.
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 four 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:
- spray shielding on piping at 694' elevation;
- operability evaluation 14-002, Rev. 0;
- Unit 1 B average power range monitor;
- seismic monitoring system computer; and
- operability evaluation 12-002, Rev. 0.
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 TSs 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 five samples as defined in IP 71111.15-05.
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 2 main turbine, control valve 2;
- Unit 2 EC 402867, temporary configuration change process (TCCP) to remove valves 2B33-F080B and 2B33-F081B from the inspection port on valve 2B33-F067B bonnet;
- Unit 2 core standby cooling system pump room damper replacement 2VD0JC;
- Unit 2, Train B starting air receiver relief valve maintenance 2E22-F370B;
- Unit 2 traversing incore probe (TIP) shear valve replacement 2C51-J004A;
- Unit 1 safety relief valve F following pressure switch replacement; and
- Unit 2, Train B reactor protection system motor-generator set replacement.
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 eight post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R20 Outage Activities
.1 Other Outage Activities
a. Inspection Scope
The inspectors evaluated outage activities for planned maintenance outage L2M18 from August 7 to 14, 2015. The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule.
The inspectors observed or reviewed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, selected clearances, control and monitoring of decay heat removal, control of containment activities, personnel fatigue management, startup and heatup activities, and identification and resolution of problems associated with the outage. Specifically, the outage was performed to facilitate the repair and restoration of the 2B reactor recirculating pump as well as to repair additional degraded equipment in the reactor recirculation and feedwater systems. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one other outage sample as defined in IP 71111.20-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following 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:
- Unit 1 HPCS operability and inservice testing (Routine);
- Unit 0 diesel operability surveillance (Routine);
- Unit 0 diesel generator idle start (Routine);
- Unit 2 RCIC (Routine);
- Unit 2 Train A RHR system biennial (Routine); and
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the 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 five routine surveillance testing samples, and one in-service test sample as defined in IP 71111.22, Sections -02 and -05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on July 31, 2015, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the licensed operator requalification training 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 Attachment to this report.
This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-06.
b. Findings
No findings were identified.
.2 Training Observation
a. Inspection Scope
The inspector observed a simulator training evolution for licensed operators on September 16, 2015, 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 71114.06-06.
b. Findings
No findings were identified.
RADIATION SAFETY
2RS1 Radiological Hazard Assessment and Exposure Controls
This inspection constituted a partial sample as defined in IP 71124.01-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed all licensee PIs for the Occupational Exposure Cornerstone for follow-up. The inspectors reviewed the results of radiation protection program audits (e.g., licensees quality assurance audits or other independent audits). The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection. The inspectors reviewed the results of the audit and operational report reviews to gain insights into overall licensee performance.
b. Findings
No findings were identified.
.2 Radiological Hazard Assessment (02.02)
a. Inspection Scope
The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether the licensee assessed the potential impact of these changes and has implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard.
b. Findings
No findings were identified.
.3 Instructions to Workers (02.03)
a. Inspection Scope
The inspectors reviewed selected occurrences where a workers electronic personal dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether workers responded appropriately to the off-normal condition. The inspectors assessed whether the issue was included in the CAP and dose evaluations were conducted as appropriate.
b. Findings
No findings were identified.
.4 Radiological Hazards Control and Work Coverage (02.05)
a. Inspection Scope
The inspectors examined the licensees physical and programmatic controls for highly activated or contaminated materials (i.e., nonfuel) stored within spent fuel and other storage pools. The inspectors assessed whether appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from the pool.
The inspectors examined the posting and physical controls for selected high radiation areas and very high radiation areas to verify conformance with the occupational PI.
b. Findings
No findings were identified.
.5 Risk-Significant High Radiation Area and Very High Radiation Area Controls (02.06)
a. Inspection Scope
The inspectors discussed with the radiation protection (RP) manager the controls and procedures for high risk, high radiation areas and very high radiation areas. The inspectors discussed methods employed by the licensee to provide stricter control of very high radiation area access as specified in 10 CFR 20.1602, Control of Access to Very High Radiation Areas, and Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas of Nuclear Plants. The inspectors assessed whether any changes to licensee procedures substantially reduce the effectiveness and level of worker protection.
The inspectors discussed the controls in place for special areas that have the potential to become very high radiation areas during certain plant operations with first-line health physics supervisors (or equivalent positions having backshift health physics oversight authority). The inspectors assessed whether these plant operations required communication beforehand with the health physics group, so as to allow corresponding timely actions to properly post, control, and monitor the radiation hazards including re-access authorization.
The inspectors evaluated licensee controls for very high radiation areas and areas with the potential to become a very high radiation areas to ensure that an individual was not able to gain unauthorized access to the very high radiation areas.
b. Findings
No findings were identified.
.6 Radiation Protection Technician Proficiency (02.08)
a. Inspection Scope
The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be RP technician error. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.
b. Findings
No findings were identified.
2RS2 Occupational As-Low-As-Is-Reasonably-Achievable Planning and Controls
This inspection constituted one complete sample as defined in IP 71124.02-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors reviewed the plants 3-year rolling average collective exposure.
The inspectors reviewed the site-specific trends in collective exposures and source term measurements.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures as-low-as-is-reasonably-achievable (ALARA), which included a review of processes used to estimate and track exposures from specific work activities.
b. Findings
No findings were identified.
.2 Radiological Work Planning (02.02)
a. Inspection Scope
The inspectors selected the following work activities of the highest exposure significance.
- L2R15 drywell safety relief valves;
- L2R15 2B33-F-67B disassembly and repair;
- L2R15 refuel floor activities; and
- L2R15 reactor cavity work platform activities.
The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements. The inspectors determined whether the licensee reasonably grouped the radiological work into work activities based on historical precedence, industry norms, and/or special circumstances.
The inspectors assessed whether the licensees planning identified appropriate dose mitigation features, considered alternate mitigation features, and defined reasonable dose goals. The inspectors evaluated whether the licensees ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment (e.g., ice vests). The inspectors determined whether the licensees work planning considered the use of remote technologies (e.g., teledosimetry, remote visual monitoring, and robotics) as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons-learned. The inspectors assessed the integration of ALARA requirements into work procedure and radiation work permit documents.
The inspectors compared the results achieved (dose rate reductions and person-rem used) with the intended dose established in the licensees ALARA planning for these work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the RP group with the actual work activity time requirements and evaluated the accuracy of these time estimates. The inspectors assessed the reasons (e.g., failure to adequately plan the activity and failure to provide sufficient work controls) for any inconsistencies between intended and actual work activity doses.
The inspectors determined whether post-job reviews were conducted and if identified problems were entered into the licensees CAP.
b. Findings
No findings were identified.
.3 Verification of Dose Estimates and Exposure Tracking Systems (02.03)
a. Inspection Scope
The inspectors reviewed the assumptions and basis (including dose rate and person-hour estimates) for the current annual collective exposure estimate for reasonable accuracy for select ALARA work packages. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and the intended dose outcome.
The inspectors evaluated whether the licensee established measures to track, trend, and, if necessary, to reduce occupational doses for ongoing work activities. The inspectors assessed whether trigger points or criteria were established to prompt additional reviews and/or additional ALARA planning and controls.
The inspectors evaluated the licensees method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered. The inspectors assessed whether adjustments to exposure estimates (intended dose) were based on sound RP and ALARA principles or if they were just adjusted to account for failures to control the work. The inspectors evaluated whether the frequency of these adjustments called into question the adequacy of the original ALARA planning process.
b. Findings
No findings were identified.
.4 Source Term Reduction and Control (02.04)
a. Inspection Scope
The inspectors used licensee records to determine the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure. The inspectors assessed whether the licensee had made allowances or developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.
b. Findings
No findings were identified.
.5 Problem Identification and Resolution (02.06)
a. Inspection Scope
The inspectors evaluated whether problems associated with ALARA planning and controls were being identified by the licensee at an appropriate threshold, and were properly addressed for resolution in the licensees CAP.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation
This inspection constituted one complete sample as defined in IP 71124.05-05.
.1 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down effluent radiation monitoring systems, including at least one liquid and one airborne system. Focus was placed on flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors of the selected systems. The inspectors assessed whether the effluent/process monitor configurations aligned with Offsite Dose Calculation Manual (ODCM) descriptions and observed monitors for degradation and out-of-service tags.
The inspectors selected portable survey instruments that were in use or available for issuance and assessed calibration and source check stickers for currency as well as instrument material condition and operability.
b. Findings
No findings were identified.
.2 Calibration and Testing Program (02.03)
Process and Effluent Monitors
a. Inspection Scope
The inspectors selected effluent monitor instruments (such as gaseous and liquid) and evaluated whether channel calibration and functional tests were performed consistent with Radiological Effluent Technical Specifications (RETS)/ODCM. The inspectors assessed whether:
- (a) the licensee calibrated its monitors with National Institute of Standards and Technology traceable sources;
- (b) the primary calibrations adequately represented the plant nuclide mix;
- (c) when secondary calibration sources were used, the sources were verified by the primary calibration; and
- (d) the licensees channel calibrations encompassed the instruments alarm setpoints.
The inspectors assessed whether the effluent monitor alarm setpoints were established as provided in the ODCM and station procedures.
For changes to effluent monitor setpoints, the inspectors evaluated the basis for changes to ensure that an adequate justification existed.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
This inspection constituted one complete sample as defined in IP 71124.06-05.
.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 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 selected 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.
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 NUREGs 1301, 1302, and 0133, and 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 has identified any non-radioactive systems that have become contaminated as disclosed either through an event report or the ODCM since the last inspection. This review provided an efficient 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.
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.
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.
.2 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 align with the documents reviewed in 02.01 above and to assess equipment material condition.
Special attention was given 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 which 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 has made significant changes to their effluent release points (e.g., changes subject to a 10 CFR 50.59 review or requiring NRC approval of alternate discharge points).
As available, the inspectors observed selected portions of the routine processing and discharging of liquid waste (including sample collection and analysis) to determine if 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.
.3 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 was performed consistent with the radiological effluent TSs/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.
.4 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 radiological effluent TSs/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
a. 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 Standby Gas Treatment System and the Containment/
Auxiliary Building Ventilation System, met TS acceptance criteria.
b. Findings
No findings were identified.
.5 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 five, 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.
Inspectors evaluated the methods used to determine the isotopes that are included in the source term to ensure all applicable radionuclides were included within detectability standards. The review included the current Part 61 analyses to ensure hard-to-detect radionuclides were included in the source term.
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. 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 Appendix I of 10 CFR Part 50 and TS dose criteria.
The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to ensure the abnormal discharge was monitored by the discharge point effluent monitor.
Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to satisfy 10 CFR 20.1501 so as to account for the source term and projected doses to the public.
b. Findings
No findings were identified.
.6 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 assessing 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 on-site groundwater sample results and a description of any significant onsite leaks/spills into ground water 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 RETSs.
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 point.
b. Findings
No findings were identified.
.7 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.
2RS7 Radiological Environmental Monitoring Program
This inspection constituted one complete sample as defined in IP 71124.07-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the annual radiological environmental operating reports and the results of any licensee assessments since the last inspection to assess whether the radiological environmental monitoring program was implemented in accordance with the TSs and ODCM. This review included reported changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data.
The inspectors reviewed the ODCM to identify locations of environmental monitoring stations.
The inspectors reviewed the UFSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation.
The inspectors reviewed quality assurance audit results of the program to assist in choosing inspection smart samples. The inspectors also reviewed audits and technical evaluations performed on the vendor laboratory, if used.
The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine if the licensee was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.
b. Findings
No findings were identified.
.2 Site Inspection (02.02)
a. Inspection Scope
The inspectors walked down select air sampling stations and dosimeter monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition. Consistent with smart sampling, the air sampling stations were selected based on the locations with the highest X/Q, D/Q wind sectors, and dosimeters were selected based on the most risk-significant locations (e.g.,
those that have the highest potential for public dose impact).
For the air samplers and dosimeters selected, the inspectors reviewed the calibration and maintenance records to evaluate whether they demonstrated adequate operability of these components. Additionally, the review included the calibration and maintenance records of select composite water samplers.
The inspectors assessed whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station.
The inspectors observed the collection and preparation of environmental samples from different environmental media (e.g., ground and surface water, milk, vegetation, sediment, and soil) as available to determine if environmental sampling was representative of the release pathways as specified in the ODCM and if sampling techniques were in accordance with procedures.
Based on direct observation and review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments in the control room and, if applicable, at the tower were operable.
The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement to determine if the licensee had identified the cause and had implemented corrective actions. The inspectors reviewed the licensees assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection) and reviewed the associated radioactive effluent release data for released material.
The inspectors selected SSCs that involved or could reasonably have involved licensed material for which there was a credible mechanism for licensed material to reach groundwater, and assessed whether the licensee had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to groundwater.
The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.
The inspectors reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection. They reviewed technical justifications for any changed sampling locations to evaluate whether the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.
The inspectors assessed whether the appropriate detection sensitivities with respect to TS/ODCM where used for counting samples (i.e., the samples meet the TS/ODCM required lower limits of detection). The inspectors reviewed quality control charts for maintaining radiation measurement instrument status and actions taken for degrading detector performance. The licensee used a vendor laboratory to analyze the radiological environmental monitoring program samples so the inspectors reviewed the results of the vendors quality control program, including the interlaboratory comparison, to assess the adequacy of the vendors program.
The inspectors reviewed the results of the licensees interlaboratory comparison program to evaluate the adequacy of environmental sample analyses performed by the licensee. The inspectors assessed whether the interlaboratory comparison test included the media/nuclide mix appropriate for the facility. If applicable, the inspectors reviewed the licensees determination of any bias to the data and the overall effect on the radiological environmental monitoring program.
b. Findings
No findings were identified.
.3 Identification and Resolution of Problems (02.03)
a. Inspection Scope
The inspectors assessed whether problems associated with the radiological environmental monitoring program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP.
Additionally, they assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the radiological environmental monitoring program.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance IndexEmergency AC Power System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC Power System PI for Units 1 and 2 for the third quarter 2014 through the second quarter 2015. To determine the accuracy of the PI data reported, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports, and NRC Integrated Inspection Reports for July 2014 through June 2015 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI emergency AC power system samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance IndexHigh Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems PI for Units 1 and 2 for the third quarter 2014 through the second quarter 2015. To determine the accuracy of the PI data reported, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports for July 2014 through June 2015 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.
The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI high pressure injection system samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance IndexResidual Heat Removal System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - RHR PI for Units 1 and 2 for the third quarter 2014 through the second quarter 2015. To determine the accuracy of the PI data, PI definitions and guidance in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports for July 2014 through June 2015 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI RHR system samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.4 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors sampled licensee submittals for the Occupational Exposure Control Effectiveness PI from the second quarter 2014 through the second quarter 2015. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the PI data reported. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine if indicator-related data were adequately assessed and reported. To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with RP staff the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one occupational exposure control effectiveness sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.5 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
Radiological Effluent Occurrences
a. Inspection Scope
The inspectors sampled licensee submittals for the RETS/ODCM radiological effluent occurrences PI from the second quarter 2014 through the second quarter 2015. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the PI data reported. 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 to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one RETS/ODCM radiological effluent occurrences sample as defined in IP 71151-05.
b. Findings
No findings 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 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
To assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants
(60855.1)
a. Inspection Scope
The inspectors observed and evaluated select licensee loading, processing, and transfer operations of multiple canisters during the licensees 2015 dry fuel storage campaign to verify compliance with the applicable Certificate of Compliance conditions, the associated TSs, and approved Independent Spent Fuel Storage Installation (ISFSI)procedures. Specifically, the inspectors observed: loading and independent verification of fuel assemblies placed into a multi-purpose canister; movement of the Holtec International transfer cask (HI-TRAC) from the spent fuel pool to the decontamination area; decontamination and surveying; welding and nondestructive testing of the multi-purpose canister lid; hydrostatic testing; vacuum drying; and restrained vertical transfer operations. The licensee used the Holtec International HI-STORM 100 Cask System for this campaign.
The inspectors reviewed procedures used to perform ISFSI preparation, loading, sealing, transfer, monitoring, and storage activities. The inspectors reviewed applicable heavy loads procedures and inspection documentation to determine compliance with the sites heavy loads program. The inspectors reviewed select documents, in part, after the licensee completed certain loading activities.
The inspectors reviewed the licensees evaluations associated with fuel characterization and selection for storage. The inspectors reviewed the licensees evaluation to characterize fuel as intact fuel, damaged fuel, or fuel debris. The licensee did not plan to load any damaged fuel assemblies or fuel debris during this campaign. The inspectors reviewed the campaign cask fuel selection packages to verify that the licensee was loading fuel in accordance with the Certificate of Compliance approved contents.
The inspectors reviewed a number of condition reports and the associated corrective actions since the last ISFSI inspection. The inspectors also reviewed 72.48 screenings and changes to the licensees 10 CFR 72.212 evaluations since the last ISFSI inspection.
The inspectors performed a walk down of the ISFSI pad to assess the material condition of the pad and the loaded HI-STORM 100 storage casks. The inspectors reviewed the licensees radiation monitoring program. Additionally, the inspectors performed independent radiation surveys around the ISFSI pad and storage casks.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 6, 2015, the inspectors presented the inspection results to Mr. P. Karaba 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 ISFSI operational inspection were presented to Site Vice President, Mr. P. Karaba, and other members of the licensees staff on August 21, 2015; and
- the inspection results for the areas of radiological hazard assessment and exposure controls; occupational ALARA planning and controls; radiation monitoring instrumentation; radioactive gaseous and liquid effluent treatment; radiological environmental monitoring; and occupational exposure control effectiveness and RETS/ODCM radiological effluent occurrences PI verification were presented to Mr. M. Vinyard, Plant Manager, on August 21, 2015.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.
ATTACHMENTS: NOTICE OF DEVIATION and
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- P. Karaba, Site Vice-President
- H. Vinyard, Plant Manager
- J. Kowalski, Engineering Manager
- K. Aleshire, Corporate Emergency Preparedness Manager
- V. Cwietniewicz, Corporate Emergency Preparedness Manager
- M. Jesse, Corporate Regulatory Assurance Manager
- G. Ford, Regulatory Assurance Manager
- J. Houston, Nuclear Oversight Manager
- J. Moser, Radiation Protection Manager
- M. Hayworth, Emergency Preparedness Manager
- G. Brumbelow, Emergency Preparedness Coordinator
- T. Dean, Operations Training Manager
- D. Wright, NRC Examination Coordinator
- L. Blunk, Regulatory Assurance
- S. Shields, Regulatory Assurance
- D. Murray, Regulatory Assurance
- B. Hilton, Design Manager
- A. Baker, Dosimetry Specialist
- J. Bauer, Training Director
- T. Dean, Operations Training Manager
- J. Shields, Program Engineering Manager
- B. Casey, Inservice Inspection
- G. Chavez, Dry Cask Storage Senior Project Manager
- S. Tutoky, Chemistry Analyst
Nuclear Regulatory Commission
- M. Kunowski, Chief, Reactor Projects Branch 5
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000373/2015003-01, DEV Failure to Maintain a Functional Ammonia Alarm
- 05000374/2015003-01 Failure to Establish Appropriate Agreements to Allow
- 05000373/2015003-02, DEV LaSalle County Station to be Notified in a Timely Manner of
- 05000374/2015003-02 a Major Offsite Anhydrous Ammonia Release
- 05000373/2015003-03, Failure to Ensure That Lease Agreements Prohibit the Use DEV
- 05000374/2015003-03 Anhydrous Ammonia Near LaSalle County Station
Closed
Both Ammonia Detectors Non-Functional on Unit 0 Train A
- 05000373/2015002-01 URI of Control Room Ventilation (1R12)