IR 05000395/2010004
| ML103020152 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/29/2010 |
| From: | Gerald Mccoy NRC/RGN-II/DRP/RPB5 |
| To: | Gatlin T South Carolina Electric & Gas Co |
| References | |
| EA-10-204 IR-10-004 | |
| Download: ML103020152 (56) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 29, 2010
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000395/2010004 AND NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000395/2010501 AND NOTICE OF VIOLATION
Dear Mr. Gatlin:
On September 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station. The enclosed inspection report documents the inspection results, which were discussed on October 14, 2010, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of the inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation and the circumstances surrounding it are described in detail in the subject inspection report. The violation involved a failure to notify the NRC with regard to a change in the medical status of a licensed operator. Although determined to be of very low safety significance (Severity Level IV), this violation is being cited in the Notice because as specified in Section 2.3.2.a.3 of the Enforcement Policy, it was (a) a repeat violation resulting from inadequate corrective action, and (b) was NRC identified. Specifically, this violation was first identified in NRC Inspection Report 05000395/2008004, and the same violation was again identified by NRC inspectors while performing a licensed operator requalification inspection. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
SCE&G 2 In addition, this report documents a licensee-identified violation which was determined to be of very low safety significance (Green). Because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Virgil C.
Summer Nuclear Station.
In accordance with 10 CFR 2.390 of the NRCs 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 (PARS) component of NRCs 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/
Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12
Enclosures:
1. Notice of Violation 2. NRC Integrated Inspection Report 05000395/2010004 and NRC Emergency Preparedness Inspection Report 05000395/2010501w/attachment: Supplemental Information
REGION II==
Docket No.: 50-395 License No.: NPF-12 Report No.: 05000395/2010004 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: July 1, 2010 through September 30, 2010 Inspectors: J. Zeiler, Senior Resident Inspector J. Polickoski, Resident Inspector D. Arnett, Project Engineer J. Beavers, Emergency Preparedness Inspector (Sections 1EP2, 1EP3, 1EP4, 1EP5, and 4OA1.2)
C. Dykes, (Sections 2, 4OA1.3, and 4OA1.4)
C. Fletcher, Senior Reactor Inspector (Section 1R17)
S. Garchow, Senior Operations Engineer (Section 1R11.2)
R. Hamilton, Senior Health Physicist (Sections 2, 4OA1.3, 4OA1.4, and 4OA5.2)
D. Jones, Senior Reactor Inspector (Section 1R17)
W. Loo, (Sections 2, 4OA1.3, 4OA1.4, and 4OA5.2)
D. Mas-Penaranda, Reactor Inspector (Section 1R17)
M. Meeks, Operations Engineer (Section 1R11.2)
A. Nielsen, (Sections 2, 4OA1.3, 4OA1.4, and 4OA5.2)
A. Sengupta, Reactor Inspector (Section 1R07)
L. Suggs, Reactor Inspector (Section 1R17)
Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure 2
SUMMARY OF FINDINGS
IR 05000395/2010004; 07/01/2010 - 09/30/2010: Virgil C. Summer Nuclear Station; Licensed
Operator Requalification.
The report covered a 3-month period of inspection by resident inspectors, a project engineer and announced inspections by regional health physics inspectors, reactor inspectors, operations engineers, and an emergency preparedness inspector. One cited Severity Level (SL) IV violation was identified. 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 aspect was 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 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-Revealing Findings
- SL IV. The inspectors identified a cited violation of 10 CFR Part 55.25,
Incapacitation because of disability or illness, for the failure of the facility licensee to notify the Commission of a change in the medical status of one licensed operator within 30 days of learning of the change as required. This issue was entered into the licensees corrective action program as Condition Report CR-10-03348.
The failure of the facility licensee to notify the Commission within 30 days of learning of a permanent change in the medical status of a licensed operator as required by 10 CFR 55.25 was a performance deficiency. This performance deficiency was evaluated in accordance with the Enforcement Policy and determined to be a Severity Level IV violation in accordance with Supplement I. This violation is being cited in accordance with the Enforcement Policy Section 2.3.2.a.3 because it was a repetitive violation resulting from inadequate corrective action and was NRC identified. Because this Notice of Violation was evaluated in accordance with Traditional Enforcement, there was no cross-cutting aspect assigned. (Section 1R11.2)
Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at full Rated Thermal Power (RTP). Between July 30 and August 27, the unit was down powered slightly on several occasions to ensure the average circulating water discharge temperature limit would not be exceeded. On September 23, a planned shutdown to Mode 3 was initiated to investigate a low oil level alarm on the A reactor coolant pump motor upper oil reservoir. The reactor was restarted on September 25 following the completion of oil leakage repairs and was returned to full RTP on September 26. The unit operated at full RTP for the remainder of the period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
Actual Adverse Weather Conditions
a. Inspection Scope
The inspectors performed an impending adverse weather inspection to review the licensees overall preparations and protection of employees and risk-significant systems in response to potential impact from Hurricane Earl. The inspectors verified the licensee had implemented applicable sections of operations administrative procedure (OAP)-
109.1, Revision (Rev.) 3A, Guidelines for Severe Weather, and emergency planning procedure (EPP)-015, Rev. 17, Natural Emergency. The inspectors walked down site outside areas and monitored licensee response actions and weather report updates until the adverse weather conditions were over.
b. Findings
No findings were identified.
1R04 Equipment Alignment
a. Inspection Scope
The inspectors conducted three partial equipment alignment walkdowns which are listed below, to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service (OOS). Correct alignment and operating conditions were determined from the applicable portions of drawings, system operating procedures (SOPs), updated final safety analysis report (UFSAR), and technical specifications (TS). The inspections included review of outstanding maintenance work orders (WOs) and related condition reports (CRs) to verify that the licensee had properly identified and resolved equipment alignment problems that could lead to the initiation of an event or impact mitigating system availability. Documents reviewed are listed in the attachment.
- B service water (SW) and service water booster pumps (SWBP) while A SWBP was OOS for scheduled maintenance
- A motor driven emergency feedwater (MDEFW) pump and turbine driven emergency feedwater (TDEFW) pump while B MDEFW pump was OOS for scheduled maintenance
b. Findings
No findings were identified.
1R05 Fire Protection
a. Inspection Scope
The inspectors reviewed recent CRs, WOs, and impairments associated with the fire protection system. The inspectors reviewed surveillance activities to determine whether they supported the operability and availability of the fire protection system. The inspectors assessed the material condition of the active and passive fire protection systems and features and observed the control of transient combustibles and ignition sources. The inspectors conducted routine inspections of the following five areas (respective fire zones also noted):
- Service water pumphouse (SWPH) (fire zones SWPH-1, 3, 4, 5.1 and 5.2)
- Intermediate building (IB) 412 elevation (fire zones IB-25.1.1, 1.2, 1.3 and IB-1.5)
- 1DA switchgear room (fire zone IB-20)
- A and B chilled water pump rooms (fire zones IB-7.2, IB-9 and IB-23.1)
- TDEFW pump room (fire zone IB-25.2)
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Annual Review of Electrical Manholes
a. Inspection Scope
The inspectors reviewed and observed licensee periodic inspection of eight electrical manholes (i.e., EMH-0011, EMH0017, EMH0019, EMH-0023, EMH-0025, EMH-0026, EMH-0033, and EMH-0042) to assess the condition of electrical cables located inside the underground manholes. The inspectors verified by direct observation that the cables, splices, support structures, and sump pumps located within the manholes appeared intact and the cables were not being impacted by water. In addition, the inspectors reviewed several past periodic licensee inspection results for each of the
above mentioned manholes to ensure that any degraded conditions identified were appropriately resolved.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
Triennial Review of Heat Sink Performance
a. Inspection Scope
The inspectors reviewed operability determinations, completed surveillances, vendor manual information, associated calculations, performance test results and cooler inspection results associated with the A and B CCW heat exchangers (HXs), the A and B Residual Heat Removal (RHR) HXs, the A and B emergency diesel generator (EDG) intercooler HXs, and the 1B Containment Cooler HX. These heat exchangers/coolers were chosen based on their risk significance in the licensees probabilistic safety analysis, their important safety-related mitigating system support functions and their relatively low margin.
For the CCW, the EDG intercooler heat exchanger, and the 1B Containment Cooler heat exchangers, the inspectors determined whether testing, inspection, maintenance, and monitoring of biotic fouling and macrofouling programs were adequate to ensure proper heat transfer. This was accomplished by determining whether the test method used was consistent with accepted industry practices, or equivalent, the test conditions were consistent with the selected methodology, the test acceptance criteria were consistent with the design basis values, and reviewing results of heat exchanger performance testing. The inspectors also determined whether the test results appropriately considered differences between testing conditions and design conditions, the frequency of testing based on trending of test results was sufficient to detect degradation prior to loss of heat removal capabilities below design basis values and test results considered test instrument inaccuracies and differences.
For the CCW, the EDG intercooler heat exchangers, the 1B Containment Cooler heat exchanger, and the RHR heat exchanger, the inspectors reviewed the methods and results of heat exchanger performance inspections. The inspectors determined whether the methods used to inspect and clean heat exchangers were consistent with as-found conditions identified and expected degradation trends and industry standards, the licensees inspection and cleaning activities had established acceptance criteria consistent with industry standards, and the as-found results were recorded, evaluated, and appropriately dispositioned such that the as-left condition was acceptable.
In addition, the inspectors determined whether the condition and operation of the CCW, the EDG intercooler heat exchangers, the 1B Containment Cooler heat exchanger, and the RHR heat exchangers, were consistent with design assumptions in heat transfer calculations and as described in the UFSAR. This included determining whether the
number of plugged tubes was within pre-established limits based on capacity and heat transfer assumptions. The inspectors determined whether the licensee evaluated the potential for water hammer and established adequate controls and operational limits to prevent heat exchanger degradation due to excessive flow induced vibration during operation. Eddy current test reports and visual inspection records were reviewed to determine the structural integrity of the heat exchanger. In addition, the inspectors determined whether the licensees chemical treatment programs for corrosion control were consistent with industry norms, and implemented accordingly.
The inspectors determined whether the performance of ultimate heat sinks (UHS) and their subcomponents such as piping, intake screens, pumps, valves, etc. was appropriately evaluated by tests or other equivalent methods to ensure availability and accessibility to the in-plant cooling water systems. For an above-ground UHS encapsulated by embankments, weirs or excavated side slopes, the inspectors reviewed the VC Summer Nuclear Power Plant Dam Safety and Inspection report performed on April 2009 by the Federal Energy Regulatory Commission (FERC).
The inspectors reviewed the licensees operation of service water system and UHS.
This included a review of licensees procedures for a loss of the service water system or UHS and the verification that instrumentation, which is relied upon for decision making, was available and functional. In addition, the inspectors determined whether macrofouling was adequately monitored, trended, and controlled by the licensee to prevent clogging. The inspectors determined whether the licensees biocide treatments for biotic control were adequately conducted and whether the results were adequately monitored, trended, and evaluated. The inspectors also reviewed strong pump / weak pump interaction and design changes to the service water system and the UHS.
The inspectors reviewed the licensees performance testing of service water system and UHS results. This included a review of the licensees performance test results for key components and service water flow balance test results. In addition, the inspectors compared the flow balance results to system configuration and flow assumptions during design basis accident conditions. The inspectors also determined whether the licensee ensured adequate isolation during design basis events, consistency between testing methodologies and design basis leakage rate assumptions, and proper performance of risk significant non-safety related functions.
The inspectors performed a system walkdown on service water and/or closed cooling water systems to determine whether the licensees assessment on structural integrity was adequate. In addition, the inspectors reviewed available licensees testing and inspections results, licensee's disposition of any active thru wall pipe leaks, and the history of thru wall pipe leakage to identify any adverse trends since the last NRC inspection. For closed cooling water systems, the inspectors reviewed operating logs or interviewed operators or system engineer, to identify adverse make-up trends that could be indicative of excessive leakage out of the closed system. For buried or inaccessible piping, the inspectors reviewed the licensee's pipe testing, inspection, or monitoring program to determine whether structural integrity was ensured and that any leakage or degradation was appropriately identified and dispositioned by the licensee.
The inspector performed a system walkdown of the service water intake structure to determine whether the licensees assessment on structural integrity and component functionality was adequate and that the licensee ensured proper functioning of traveling screens and strainers, and structural integrity of component mounts. In addition, the inspectors determined whether service water pump bay silt accumulation was monitored, trended, and maintained at an acceptable level by the licensee, and that water level instruments were functional and routinely monitored. The inspectors also determined whether the licensees ability to ensure functionality during adverse weather conditions was adequate.
In addition, the inspectors reviewed condition reports related to the heat exchangers/coolers and heat sink performance issues to determine whether the licensee had an appropriate threshold for identifying issues and to evaluate the effectiveness of the corrective actions. The documents that were reviewed are included in the attachment to this report.
These inspection activities constituted seven heat sink inspection samples as defined in Inspection Procedure (IP) 71111.07-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Resident Inspector Observations
a. Inspection Scope
On August 17, 2010, the inspectors observed the performance of senior reactor operators and reactor operators on the plant simulator during licensed operator requalification annual examinations. The scenario involved a feedwater heater transient, reactor coolant pump seal failure, and a large break loss-of-coolant-accident complicated by containment recirculation screen blockage. The inspectors assessed overall crew performance, communications, oversight of supervision, and the evaluators' critique. The inspectors verified that any significant training issues were appropriately captured in the licensees corrective action program (CAP).
b. Findings
No findings were identified.
.2 Licensed Operator Requalification
a. Inspection Scope
The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of August 23, 2010, the inspectors
reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, Operators Licenses. The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and IP 71111.11, Licensed Operator Requalification Program. The inspectors also evaluated the licensees simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5-1985, American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination. The inspectors observed one crew during the performance of the operating tests. Documentation reviewed included written examinations, Job Performance Measures (JPMs), simulator scenarios, licensee procedures, on-shift records, simulator deficiency records, simulator performance test records, operator feedback records, licensed operator qualification records, remediation plans, watchstanding records, and medical records. The records were inspected using the criteria listed in IP 71111.11. Documents reviewed during the inspection are documented in the attachment.
b. Findings
Failure to Notify the Commission of a Change in Medical Status
Introduction:
The NRC inspectors identified a cited Severity Level IV violation of 10 CFR Part 55.25, Incapacitation because of disability or illness. Specifically, the facility licensee failed to notify the Commission of a permanent change in the medical status of one licensed operator within 30 days of learning of the change as required.
Description:
The inspectors identified a failure of the licensee to notify the NRC of a change in medical status of one licensed operator that would have potentially resulted in an additional restriction placed on the individuals operator license.
The medical requirements applicable to individuals holding licenses to operate the controls of a nuclear power plant are contained in 10 CFR Part 55 Subpart C-Medical Requirements. 10 CFR 55.21, Medical examination, states, in part, that A licensee shall have a medical examination by a physician every two years. The physician shall determine that the applicant or licensee meets the requirements of § 55.33(a)(1). The facility licensee was committed to meet the medical requirements of 10 CFR 55.21 using ANSI/ANS-3.4-1983, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. Section 2.2 of this standard defines solo operation as follows: Operation of the controls, including monitoring of instrumentation during steady state operations, with no other qualified person in the control room or other specified control areas, such as the refueling console. Moreover, section 5.1 of ANSI/ANS-3.4-1983 states, in part, that The potential consequences of insidious incapacitation are most serious in solo operation, but shall be considered in any facility.
Many of the conditions indicated above may be accommodated by restricting the activities of the individual, requiring close surveillance of the condition, imposing a
temporary medical regime, or requiring another individual to be present when the individual in question is performing his assigned duties. The facility licensee administratively meets the requirement for a medical examination every two years by requiring each licensed operator to have a medical examination approximately once every calendar year.
10 CFR 55.23, Certification, further requires that To certify the medical fitness of the applicant, an authorized representative of the facility licensee shall complete and sign NRC Form 396, Certification of Medical Examination by Facility Licensee, .
- (a) Form NRC-396 must certify that a physician has conducted the medical examination of the applicant as required in § 55.21;
- (b) When the certification requests a conditional license based on medical evidence, the medical evidence must be submitted on NRC Form 396 to the Commission and the Commission then makes a determination in accordance with § 55.33. Furthermore, 10 CFR 55.25 states, in part, that If, during the term of the license, the licensee develops a permanent physical or mental condition that causes the licensee to fail to meet the requirements of § 55.21 of this part, the facility licensee shall notify the Commission, within 30 days of learning of the diagnosis, in accordance with § 50.74(c). For conditions for which a conditional license (as described in § 55.33(b) of this part) is requested, the facility licensee shall provide medical certification on Form NRC 396 to the Commission (as described in § 55.23 of this part).
NRC Region II issued a license amendment to the individual in question effective August 31, 2009, requiring the individual to comply with three conditions; namely, that he shall wear corrective lenses while performing licensed operator duties, that he shall not perform any licensed activities that require use of a respirator, and that he shall take medication as prescribed. On September 9, 2009, the individual had a licensed operator medical evaluation performed by the facility licensees medical review officer. The medical review officer identified the three conditions listed above, and also determined that an additional medical restriction-for no solo operation-was also required based on the individuals medical examination.
During the week of August 23, 2010, while performing a review of a random sample of 14 licensed operator medical records, including the above individual, as part of IP 71111.11, the inspectors noted the individual had a no solo restriction identified by the facility licensees medical review officer that was not reflected in the Operator Licensing Tracking System (OLTS) database maintained by the NRC. The inspectors determined that the discrepancy was because the NRC had not been notified of the change in the licensed operators medical status. Based on interviews and discussions with facility licensee personnel, the inspectors determined that due to the individuals medical restrictions, the individual was taken off the regular control room licensed operator watch bill; the operators license was administratively declared inactive; and the individual was being used exclusively in an operations support position, e.g. to prepare and review clearance orders and work management.
After discussing the issue with the Senior Resident Inspector, the inspectors reviewed Integrated Inspection Report 05000395/2008004, dated October 30, 2008, and determined that the same issue was documented in this report as a Severity Level IV Non-Cited Violation (NCV). This report documented a licensee-identified NCV of CFR 55.25 for failing to notify the Commission when eleven licensed operators were diagnosed with a permanent physical medical condition within 30 days as required by 10 CFR 55.25. This finding was identified by the licensee in CR-08-00080 and CR-05-03172.
Therefore, because this issue was
- (a) a repeat violation resulting from inadequate corrective action, and
- (b) NRC-identified, the inspectors determined that this issue needed to be cited as a Severity Level IV Notice of Violation (NOV).
Analysis:
The inspectors initially screened the issue using Appendix B, Issue Screening, of Inspection Manual Chapter (IMC) 0612. The inspectors then determined that the failure of the facility licensee to notify the Commission within 30 days of discovering a permanent change in the medical status of a licensed operator, as required by 10 CFR 55.25, was a performance deficiency. The inspectors determined that the cause of the performance deficiency was reasonably within the licensees ability to foresee and correct, and therefore should have been prevented.
The inspectors then determined that the performance deficiency, involving a violation of 10 CFR 55.25, impacted the regulatory process; and would therefore be dispositioned using Traditional Enforcement (TE). In accordance with Section 2.2.2, Severity Levels, of the NRCs Enforcement Policy, the inspectors reviewed the violation against the examples listed in Section 6.0, and determined that the violation was of very low safety significance (Severity Level IV) because a physical examination required by 10 CFR Part 55 was not reported to the Commission. This constituted a more than minor concern because a change in medical status would have required Commission review and approval and would have resulted in change to the operators license restrictions. In accordance with Section 2.3.2.a.3 of the Enforcement Policy, the inspectors determined that the violation was repetitive as a result of inadequate corrective action, and was identified by the NRC. Therefore, the violation met the requirements to be cited as a Severity Level IV NOV. The inspectors did not identify a cross-cutting aspect associated with this violation because the NOV was evaluated exclusively using TE, in accordance with IMC 0612 section 06.03.c.
Enforcement:
Title 10 CFR Part 55.25, Incapacitation because of disability or illness, requires, in part, that if a licensed operator develops a permanent physical or mental condition that causes the licensed operator to fail to meet the requirements of 55.21, the facility licensee shall notify the Commission within 30 days of learning of a diagnosis.
Contrary to the above, from September 9, 2009, to August 26, 2010, the facility licensee failed to notify the Commission within 30 days of learning of the diagnosis that a licensed operator had developed a permanent physical or mental condition that caused the licensed operator to fail to meet the requirements of 55.21. Specifically, the licensed operator was placed in a no-solo status by the facility licensees medical review officer due to a permanent change in the individuals medical condition without notifying the Commission as required. This finding was determined to be of very low safety significance because the licensed operator was removed from the list of active license holders, and the issue was entered into the corrective action program as CR-10-03348.
Therefore, this violation of 10 CFR 55.25 was classified as a Severity Level IV violation.
However, because this violation was
- (a) a repeat violation resulting from inadequate
corrective action, and
- (b) NRC identified, this violation is being cited in a NOV, consistent with Section 2.3.2.a.3 of the NRC Enforcement Policy.
(VIO 05000395/2010004-01): Failure to Notify the Commission of a Change in Medical Status
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated two equipment issues described in the CRs listed below to verify the licensees effectiveness with the corresponding preventive or corrective maintenance associated with structures, systems, and components (SSCs). The inspectors reviewed Maintenance Rule (MR) implementation to verify that component and equipment failures were identified, entered, and scoped within the MR program.
Selected SSCs were reviewed to verify proper categorization and classification in accordance with 10 CFR 50.65. The inspectors examined the licensees 10 CFR 50.65(a)(1) corrective action plans to determine if the licensee was identifying issues related to the MR at an appropriate threshold and that corrective actions were established and effective. The inspectors review also evaluated if maintenance preventable functional failures (MPFFs) or other MR findings existed that the licensee had not identified.
The inspectors reviewed the licensees controlling procedures, i.e., engineering services procedure (ES)-514, Rev. 4, Maintenance Rule Implementation, and the Virgil C.
Summer Important To Maintenance Rule System Function and Performance Criteria Analysis, to verify consistency with the MR requirements.
- CR-10-00632, A EDG cooling water leakage from jacket water pump seal
- CR-10-01427, emergency feedwater air supply relief valve XVR03541-EF failure
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors evaluated, as appropriate, for the five selected work activities listed below:
- (1) the effectiveness of the risk assessments performed before maintenance activities were conducted;
- (2) the management of risk;
- (3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and,
- (4) that emergent work problems were adequately identified and resolved. The inspectors evaluated the licensees work prioritization and risk characterization to determine, as appropriate, whether necessary steps were properly planned, controlled, and executed for the planned and emergent work activities.
- Work Week 2010-28: risk assessment for scheduled maintenance and testing on the A SW pump, the A SWBP, the A MDEFW pump, B instrument air compressor, and a reactor building entry
- Work Week 2010-34: risk assessment for scheduled maintenance for the annual overhaul/inspection of the B chiller, B chilled water pump preventive maintenance, C CCW and C CCW booster pump preventive maintenance, and emergent work to repair A centrifugal charging pump lube oil leak
- Work Week 2010-38: risk assessment for scheduled maintenance for the replacement of the A chiller, switchyard relay house replacement modification (yellow risk), diver inspections of the SW pond, B SWBP and associated room cooling unit preventive maintenance, B MDEFW pump and associated room cooling unit preventive maintenance, switchyard AC power Bus #3 de-energization and preventive maintenance (yellow risk), and B reactor building spray pump electrical preventive maintenance
- Work Week 2010-39: risk assessment for scheduled maintenance for the switchyard relay house replacement modification (yellow risk), replacement of the A chiller, safety-related transformer XTF005 relay testing, and plant shutdown/restart to investigate/repair reactor coolant pump motor oil leakage
- Work Week 2010-40: risk assessment for scheduled maintenance to replace the A SW pump motor upper oil cooling coil (yellow risk), switchyard relay house replacement modification (yellow risk), pressurizer heater capacity testing, and A MDEFW pump testing
b. Findings
No findings were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed four operability evaluations listed below, affecting risk significant mitigating systems to assess, as appropriate:
- (1) the technical adequacy of the evaluations;
- (2) whether operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred;
- (3) whether other existing degraded conditions were considered;
- (4) that the licensee considered other degraded conditions and their impact on compensatory measures for the condition being evaluated; and,
- (5) the impact on TS limiting conditions for operations and the risk significance in accordance with the significance determination process. Also, the inspectors verified that the operability evaluations were performed in accordance with station administrative procedure (SAP)-209, Revision 0E, Operability Determination Process, and SAP-999, Rev. 4D, Corrective Action Program.
- CR-04-03328, resolution of operator timeline and dose calculations for steam generator tube rupture
- CR-10-02845, Pressurizer safety valve open indication acoustic monitoring alarm received
- CR-10-03329, A reactor building cooling unit service water return isolation valve, XVB03107A, exceeded its stroke time limit
- CR-10-03724, A MDEFW pump inboard bearing temperature reached the high warning temperature indication on the plant computer
b. Findings
No findings were identified.
1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed selected samples of evaluations to confirm that the licensee had appropriately considered the conditions under which changes to the facility, UFSAR, or procedures may be made, and tests conducted, without prior NRC approval. The inspectors reviewed evaluations for nine changes and additional information, such as drawings, calculations, supporting analyses, the UFSAR, and TS, to confirm that the licensee had appropriately concluded that the changes could be accomplished without obtaining a license amendment. The nine evaluations reviewed are listed in the
.
The inspectors reviewed samples of changes for which the licensee had determined that evaluations were not required, to confirm that the licensees conclusions to screen out these changes were correct and consistent with 10CFR50.59. The nineteen screened out changes reviewed are listed in the attachment.
The inspectors evaluated engineering design change packages for eight material, component, and design based modifications to evaluate the modifications for adverse effects on system availability, reliability, and functional capability. The eight modifications are as follows:
- OSC 1875 Pressure Regulator 67 CFR Used in Instrument Air Supply Line
- ECR 50585B, Reroute of Service Water and Chilled Water Piping Interferences
- ECR 50704, Reactor Vessel Upflow Conversion
- ECR 50594, RMA0011 Recorder Replacement
- ECR 50690, EDG Vacuum Switch Setpoint Input Documents reviewed included procedures, engineering calculations, modification design and implementation packages, work orders, site drawings, corrective action documents, applicable sections of the UFSAR, supporting analyses, Technical Specifications, and design basis information. The inspectors additionally reviewed test documentation to ensure adequacy in scope and conclusion. The inspectors review was also intended to
verify that all appropriate details were incorporated in licensing and design basis documents and associated plant procedures.
The inspectors also reviewed selected CRs and the licensees recent self-assessment associated with modifications and screening/evaluation issues to confirm that problems were identified at an appropriate threshold, were entered into the corrective action process, and appropriate corrective actions had been initiated and tracked to completion.
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the six maintenance activities listed below, the inspectors reviewed the associated post-maintenance testing (PMT) procedures and either witnessed the testing and/or reviewed test records to assess whether:
- (1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
- (2) testing was adequate for the maintenance performed;
- (3) test acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
- (4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
- (5) tests were performed as written with applicable prerequisites satisfied;
- (6) jumpers installed or leads lifted were properly controlled;
- (7) test equipment was removed following testing; and,
- (8) equipment was returned to the status required to perform its safety function. The inspectors verified that these activities were performed in accordance with general test procedure (GTP)-214, Rev.
5A, Post Maintenance Testing Guideline.
- WO 1009823, PMT for replacement of actuator for reactor building cooling unit service water return isolation valve XVB03107A
- WO 1000799, PMT following preventive maintenance on B SWBP
- WOs 0517868, 0715857, 0715858, 1005816, 1005819, and 1005820, PMT following electrical switchgear work and protective relay calibration associated with emergency auxiliary transformers XTF-31 and XTF-32
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors performed the inspection activities described below for the scheduled short duration outage in Hot Standby (Mode 3) to investigate a low level alarm on the A reactor coolant pump (RCP) motor upper oil reservoir and make subsequent oil leakage repairs. The outage began on September 23 and ended on September 25. Documents reviewed are listed in the attachment.
- The outage work plan was reviewed to ensure that appropriate risk controls, defense-in-depth, and TS requirements were considered in the configuration of important plant safety equipment, and outage personnel resource scheduling took into consideration fatigue management requirements
- The plant shutdown was observed to ensure that TS and licensee procedural requirements were met for controlling key safety functions and plant configuration changes, and that defense-in-depth was maintained commensurate with the licensees outage risk control and reactivity management plans
- The inspectors reviewed and observed personnel containment entries to verify that the licensee controlled the entries and work activities in accordance with the appropriate TS and licensee procedural requirements for maintaining containment integrity, foreign material exclusion, security access, and radiological controls
- The inspectors conducted several containment building walkdowns during and following the completion of licensee work activities to ensure that there was not debris left in containment that might contribute to emergency core cooling system sump screen blockage
- The inspectors observed reactor restart, mode changes, and changing plant configurations to verify that TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites were met during these activities
- The inspectors reviewed various problems that arose during the outage to verify that the licensee was identifying problems related to outage activities at an appropriate threshold and entering them into the CAP
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed and/or reviewed the six surveillance test procedures (STPs)listed below to verify that TS surveillance requirements were followed and that test acceptance criteria were properly specified to ensure that the equipment could perform its intended safety function. The inspectors verified that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria were met.
In-Service Tests:
- STP-223.002A, Rev. 9D, Service Water Pump Test (for B train)
Reactor Coolant System Leakage Tests:
- STP-114.002, Rev. 12B, Operational Leakage Calculation Other Surveillance Tests:
- STP-125.002B, Rev. 1I, Diesel Generator B Operability Test
- STP-105.006, Rev. 11E, Safety Injection / Residual Heat Removal Monthly Flow Path Verification Test
- STP-120.003, Rev. 8H, Emergency Feedwater Monthly Valve Verification
- EMP-190.053, Rev. 1A, Test Procedure for Lock-Out Relays 86T4 and 86T5 (for 86T5 relay)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Testing
a. Inspection Scope
The inspector evaluated the adequacy of licensees methods for testing the Alert and Notification System (ANS) in accordance with NRC Inspection Procedure 71114, attachment 02, Alert and Notification System Evaluation. The applicable planning standard, 10 CFR Part 50.47(b)(5), and its related requirements, 10 CFR Part 50, Appendix E, Section IV.D, were used as reference criteria. The criteria contained in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1, was also used as a reference.
The inspector reviewed various documents which are listed in the attachment. This inspection activity satisfied one inspection sample for the ANS on a biennial basis.
b. Findings
No findings were identified.
1EP3 Emergency Preparedness Organization Staffing and Augmentation System
a. Inspection Scope
The inspector reviewed the licensees Emergency Response Organization (ERO)augmentation staffing requirements and process for notifying the ERO to ensure the readiness of key staff for responding to an event and timely facility activation. The qualification records of key position ERO personnel were reviewed to ensure all ERO qualifications were current. A sample of problems identified from augmentation drills or system tests performed since the last inspection were reviewed to assess the effectiveness of corrective actions.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, attachment 03, Emergency Response Organization Staffing and Augmentation System. The applicable planning standard, 10 CFR 50.47(b)(2), and its related requirements, 10 CFR 50, Appendix E, were used as reference criteria.
The inspector reviewed various documents which are listed in the attachment to this report. This inspection activity satisfied one inspection sample for the ERO staffing and augmentation system on a biennial basis.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Since the last NRC inspection of this program area, no change has been implemented to Rev. 58 of the Radiological Emergency Response Plan. The inspector conducted a sampling review of the implementing procedure changes made between October 1, 2009, and August 31, 2010 to evaluate for potential decreases in effectiveness of the Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, attachment 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standard, 10 CFR 50.47(b)(4), and its related requirements, 10 CFR 50, Appendix E, were used as reference criteria.
The inspector reviewed various documents which are listed in the attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.
b. Findings
No findings were identified.
1EP5 Correction of Emergency Preparedness Weaknesses
a. Inspection Scope
The inspector reviewed the corrective actions identified through the Emergency Preparedness program to determine the significance of the issues and to determine if repeat problems were occurring. The facilitys self-assessments and audits were reviewed to assess the licensees ability to be self-critical, thus avoiding complacency and degradation of their emergency preparedness program. In addition, the inspector reviewed licensee self-assessments and audits to assess the completeness and effectiveness of all emergency preparedness related corrective actions.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, attachment 05, Correction of Emergency Preparedness Weaknesses. The applicable planning standard, 10 CFR 50.47(b)(14), and its related requirements, 10 CFR 50, Appendix E, were used as reference criteria.
The inspector reviewed various documents which are listed in the attachment. This inspection activity satisfied one inspection sample for the correction of emergency preparedness weaknesses on a biennial basis.
b. Findings
No findings were identified.
RADIATION SAFETY
(RS)
Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety (PS)
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
Hazard Assessment and Instructions to workers: During facility tours, the inspectors directly observed labeled radioactive material and postings for radiation areas and high radiation areas (HRAs) established within the radiologically controlled area (RCA). The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed and verified survey records for several plant areas including surveys for alpha emitters, airborne radioactivity, gamma surveys with a range of dose rate gradients. The inspectors also
discussed changes to plant operations with Radiation Protection (RP) supervisors that could contribute to changing radiological conditions since the last inspection. The inspectors attended a pre-job discussion and reviewed several radiation work permit (RWP) details to assess communication of radiological control requirements and current radiological conditions to workers.
Hazard Control and Work Practices: The inspectors evaluated access barrier effectiveness for selected Locked High Radiation Area (LHRA) and Very High Radiation Area (VHRA) locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with RP supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool were reviewed and discussed. Established radiological controls (including airborne controls) were evaluated for selected tasks including work in auxiliary building HRAs, and radwaste processing and storage. In addition, licensee controls for areas where dose rates could change significantly as a result of plant shutdown and refueling operations were reviewed and discussed.
Occupational workers adherence to selected RWPs and RP technician proficiency in providing job coverage were evaluated through direct observations and interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker stay times were evaluated against area radiation survey results for reviewed RWPs.
Control of Radioactive Material: The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors reviewed the last three cycles of calibration records for selected release point survey instruments and discussed equipment sensitivity, alarm setpoints, and release program guidance with licensee staff. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.
Problem Identification and Resolution: CRs associated with radiological hazard assessment and control were reviewed and assessed. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure SAP-999, Corrective Action Program, Rev. 4. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results.
RP activities were evaluated against the requirements of UFSAR Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee procedures.
Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in Section 2RS1 of the attachment.
The inspectors completed all specified line-items detailed in IP 71124.01 (sample size of 1).
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors evaluated current RP program activities and results associated with internal and external radiation exposure monitoring of occupational workers. The review included program guidance, equipment and changes, as applicable; quality assurance activities, results, and responses to identified issues; and individual dose results for occupational workers.
External Dosimetry: The inspectors reviewed and discussed RP program guidance for monitoring external and internal radiation exposures of occupational workers. The inspectors verified National Voluntary Laboratory Accreditation Program certification data and discussed program guidance for storage, processing and results for active and passive personnel dosimeters currently in use. Comparisons between direct reading dosimeter and thermoluminescent dosimeters (TLDs) data were reviewed and discussed.
Internal Dosimetry: Program guidance, instrument detection capabilities, and select results for the internally deposited radionuclides were reviewed in detail. The inspectors reviewed routine termination and follow-up in vivo [Whole Body Count (WBC)] analyses, as well as, in vitro bioassays conducted for tritium monitoring for divers in calendar year 2009. In addition, guidance for collection and conduct of special bioassay sampling were discussed in detail.
Special Dosimetric Situations: The inspectors reviewed monitoring conducted and results for special dosimetric situations. The methodology and results of monitoring occupational workers within non-uniform external dose fields were evaluated. In addition, the adequacy of dosimetry program guidance and its implementation were reviewed for shallow dose assessments and supporting calculations for three separate discrete radioactive particle skin contamination events which occurred during the previous refueling outage. The inspectors reviewed monitoring conducted, and results for selected declared pregnant workers documented in licensee records since January 1, 2009. In addition, proficiency of RP staff involved in conducting skin dose assessments, neutron monitoring, and WBC equipment operations were evaluated through direct interviews, onsite observations, and review and discussions of completed records and supporting data.
Problem Identification and Resolution: The inspectors reviewed and discussed selected CRs associated with occupational dose assessment. The reviewed items included CRs, self-assessments, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve identified issues in accordance with licensee procedure, SAP 999, Corrective Action Program, Rev. 4.
RP program occupational dose assessment guidance and activities were evaluated against the requirements of the UFSAR Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS4 of the attachment.
The inspectors completed all specified line-items detailed in IP 71124.04 (sample size of 1).
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a. Inspection Scope
Effluent Monitoring and Radwaste Equipment: During inspector walk-downs, accessible sections of the liquid and gaseous radioactive waste (radwaste) and effluent systems were assessed for material condition and conformance with system design diagrams.
The inspection included floor drain tanks, liquid waste system piping, waste gas decay tanks, monitor tanks, liquid radwaste monitors, plant stack effluent monitors, and associated airborne effluent sample lines. The inspectors interviewed licensee staff regarding radwaste equipment configuration and effluent monitor operation.
The inspectors reviewed performance records and calibration results for selected radiation monitors, flowmeters, and air filtration systems. For effluent monitors RMA-0003 (main plant stack), RMA-0004 (reactor building purge exhaust), RMA-6 (fuel handling building exhaust) RML-0005 (liquid waste) and RML-8 (turbine building sump)the inspectors reviewed the last two calibration records. The last two surveillances on the high efficiency particulate filter (HEPA)/Charcoal air treatment systems also were reviewed. The inspectors evaluated out-of-service effluent monitors and compensatory action data for the period January 2009 - August 2010.
Installed configuration, material condition, operability, and reliability of selected effluent sampling and monitoring equipment were reviewed against details documented in the following: 10 CFR Part 20; RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants; American Nuclear Standards Institute (ANSI)-N13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities; TS Section 5; the Offsite Dose Calculation Manual (ODCM); and UFSAR, Chapter 12. Procedures and records reviewed during the inspection are listed in Section 2RS6 of the attachment.
Effluent Release Processing and Quality Control Activities: The inspectors observed the weekly collection of liquid effluent samples from B monitor tank and effluent samples from the turbine building (condensate polisher discharge). Chemistry technician proficiency in collecting, processing, and counting the samples, as well as preparing the applicable release permits were evaluated. The inspectors reviewed recent liquid and gaseous release permits including pre-release sampling results, effluent monitor set-points, and resultant doses to the public. The inspectors also reviewed the 2008 and 2009 annual effluent reports to evaluate reported doses to the public and to review ODCM changes. The inspectors reviewed daily quality control data logs and calibration records for instruments used to quantify effluent sample activity including High Purity
Germanium detectors and liquid scintillation counters. In addition, results of the 2008, and 2009 inter-laboratory cross-check program were reviewed.
Observed task evolutions, count room activities, and offsite dose results were evaluated against details and guidance documented in the following: 10 CFR Part 20 and Appendix I to 10 CFR Part 50; ODCM; RG 1.21; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I; and TS Section 6. Procedures and records reviewed during the inspection are listed in Section 2RS6 of the attachment.
Problem Identification and Resolution: Selected CRs associated with effluent release activities were reviewed and assessed. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve selected issues in accordance with procedure SAP-999, Corrective Action Program, Rev. 4. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Reviewed documents are listed in Section 2RS6 of the attachment.
The inspectors completed one specified line-item sample as detailed in IP 71124.06 (sample size of 1).
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program (REMP)
a. Inspection Scope
REMP Implementation: The inspectors observed routine sample collection and surveillance activities as required by the licensees environmental monitoring program in the ODCM. The inspectors evaluated the location and the material condition of five air sampling stations and eight environmental TLDs. The operability of air sampling stations was verified during the observation of the weekly airborne particulate filter and iodine cartridge changes.
Land use census results, changes to the ODCM, and sample collection/processing activities were discussed with environmental technicians and licensee staff. The inspectors reviewed calendar year, and current procedural guidance for environmental sample collection and processing.
Procedural guidance, program implementation, and environmental monitoring results were reviewed against: 10 CFR Part 20; Appendix I to 10 CFR Part 50; TS Section 6.13 and 6.14, ODCM; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment; and the Branch Technical Position, An Acceptable Radiological Environmental Monitoring Program - 1979.
Documents reviewed are listed in Section 2RS7 of the attachment.
Meteorological Monitoring Program: During tours of the meteorological tower and local data collection equipment, the inspectors observed the physical condition of the tower and its instruments and discussed equipment operability and maintenance history with the responsible RP Supervisor. For the meteorological measurements of wind speed, wind direction, and temperature, the inspectors reviewed calibration records for applicable tower instrumentation and evaluated measurement data recovery.
Licensee procedures and activities related to meteorological monitoring were evaluated against: ODCM; UFSAR; ANSI/ANS-2.5-1984, Standard for Determining Meteorological Information at Nuclear Power Sites; and Safety Guide 23, Onsite Meteorological Programs. Documents reviewed are listed in Section 2RS7 of the attachment.
Problem Identification and Resolution: The inspectors reviewed selected CRs in the areas of environmental monitoring, meteorological monitoring, and release of materials.
The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with SAP-999, Corrective Action Program, Rev. 4. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Documents reviewed are listed in section 2RS7 of the attachment.
The inspectors completed all specified line-item samples detailed in Inspection Procedure (IP) 71124.07 (sample size of 1).
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation
a. Inspection Scope
Waste Processing and Characterization: During inspector walk-downs, accessible sections of the liquid and solid radioactive waste (radwaste) processing systems were assessed for material condition and conformance with system design diagrams.
Inspected equipment included radwaste storage tanks; resin transfer piping, resin and filter packaging components; and abandoned evaporator equipment. The inspectors discussed component function, processing system changes, and radwaste program implementation with licensee staff.
The 2009 Effluent Report and radionuclide characterizations from 2008 - 2010 for selected waste streams were reviewed and discussed with radwaste staff. For primary resin, reactor coolant system filters, and Dry Active Waste the inspectors evaluated analyses for hard-to-detect nuclides, reviewed the use of scaling factors, and examined quality assurance comparison results between licensee waste stream characterizations and outside laboratory data. Waste stream mixing and concentration averaging methodology for resins and filters was evaluated and discussed with radwaste staff. The
inspectors also reviewed the licensees procedural guidance for monitoring changes in waste stream isotopic mixtures.
Radwaste processing activities and equipment configuration were reviewed for compliance with the licensees Process Control Program and UFSAR, Chapter 11.
Waste stream characterization analyses were reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 61, and guidance provided in the Branch Technical Position on Waste Classification (1983). Reviewed documents are listed in Section 2RS8 of the attachment.
Radioactive Material Storage: During walk-downs of indoor and outdoor radioactive material storage areas, the inspectors observed the physical condition and labeling of storage containers and the posting of Radioactive Material Areas. The inspectors also reviewed licensee procedural guidance for storage and monitoring of radioactive material.
Radioactive material and waste storage activities were reviewed against the requirements of 10 CFR Part 20. Reviewed documents are listed in Section 2RS8 of the report attachment.
Transportation: There were no significant shipments during the week of inspection, however the inspectors did observe preparation activities for the shipment of an empty package previously used to ship radioactive material. The inspectors noted package markings and labeling, performed independent dose rate measurements, and interviewed shipping technicians regarding Department of Transportation (DOT)regulations.
Selected shipping records were reviewed for consistency with licensee procedures and compliance with NRC and DOT regulations. The inspectors reviewed emergency response information, DOT shipping package classification, waste classification, radiation survey results, and evaluated whether receiving licensees were authorized to accept the packages. Licensee procedures for handling shipping containers were compared to Certificate of Compliance requirements and manufacturer recommendations. In addition, training records for selected individuals currently qualified to ship radioactive material were reviewed.
Transportation program implementation was reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178, as well as the guidance provided in NUREG-1608. Training activities were assessed against 49 CFR Part 172 Subpart H.
Documents reviewed during the inspection are listed in Section 2RS8 of the attachment.
Problem Identification and Resolution: The inspectors reviewed CRs in the area of radwaste processing and transportation. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure SAP-999, Corrective Action Program, Rev. 4. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Licensee CAP documents reviewed are listed in Section 2RS8 of the attachment.
The inspectors completed one sample as required by IP 71124.08 (sample size of 1).
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
.1 Cornerstone Mitigating Systems
a. Inspection Scope
The inspectors verified the accuracy of the licensees PI submittals listed below for the period July 2009 through June 2010. The inspectors used the performance indicator definitions and guidance contained in NEI 99-02, Rev. 6, Regulatory Assessment Performance Indicator Guideline, and licensee procedure SAP-1360, Rev. 1, NRC and INPO/WANO Performance Indicators, to check the reporting of each data element.
The inspectors sampled licensee event reports (LERs), operator logs, plant status reports, CRs, and performance indicator data sheets to verify that the licensee had properly reported the PI data. Also, the inspectors discussed the PI data with the licensee personnel associated with the performance indicator data collection and evaluation.
- MSPI - High Pressure Safety Injection System
- MSPI - Residual Heat Removal System
b. Findings
No findings were identified.
.2 Cornerstone: Emergency Preparedness
a. Inspection Scope
The inspector sampled licensee submittals relative to the PIs listed below for the period October 1, 2009, and June 30, 2010. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 6, was used to confirm the reporting basis for each data element.
- Emergency Response Organization Drill/Exercise Performance (DEP)
- Emergency Response Organization Readiness (ERO)
- Alert and Notification System Reliability (ANS)
The inspection was conducted in accordance with NRC IP 71151, Performance Indicator Verification. For the specified review period, the inspector examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspector verified the accuracy of the PI for ERO drill and exercise performance through review of a sample of drill and event records. The inspector reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO.
The inspector verified the accuracy of the PI for alert and notification system reliability through review of a sample of the licensees records of periodic system tests. The inspector also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area are listed in the attachment.
This inspection activity satisfied one inspection sample each for the Drill/Exercise Performance, ERO Drill Participation, and Alert and Notification System as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Cornerstone: Occupational Radiation Safety
a. Inspection Scope
The inspectors sampled licensee records to verify the accuracy of reported PI data for the periods listed below. To verify the accuracy of the reported PI elements, the reviewed data were assessed against guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline," Rev. 6.
The inspectors reviewed PI data collected from January 1, 2009, through August 19, 2010, for the Occupational Exposure Control Effectiveness PI. For the reviewed period, the inspectors assessed CAP records to determine whether HRA, VHRA, or unplanned exposures, resulting in TS or 10 CFR 20 non-conformances, had occurred during the review period. In addition, the inspectors reviewed selected personnel contamination event data, internal dose assessment results, and ED alarms for cumulative doses and/or dose rates exceeding established set-points. The reviewed documents relative to this PI are listed in Sections 2RS1 and 4OA1 of the attachment.
b. Findings
No findings were identified.
.4 Cornerstone: Public Radiation Safety
a. Inspection Scope
The inspectors sampled licensee records to verify the accuracy of reported PI data for the periods listed below. To verify the accuracy of the reported PI elements, the reviewed data were assessed against guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline," Rev. 6.
The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from January 1, 2009, through August 19, 2010. For the assessment period, the inspectors reviewed cumulative and projected doses to the public, out-of-service effluent radiation monitors and compensatory sampling data, and selected CRs related to Radiological Effluent Technical Specifications/ODCM issues. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in sections 2RS6 and 4OA1 of the attachment.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.
b. Findings
No findings were identified.
.2 Annual Sample Review
a. Inspection Scope
The inspectors reviewed the issue listed below in detail to evaluate the effectiveness of the licensees corrective actions for important safety issues.
- CR-09-05093, While energizing the new main generator transformer, a loss of all balance of plant (BOP) AC power occurred
The inspectors assessed whether the issue was properly identified; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and identified appropriate and timely corrective actions. Also, the inspectors verified the issues were processed in accordance with procedure SAP-999, Rev. 4D, Corrective Action Program.
b. Findings
The inspectors identified one weakness with the licensees implementation of corrective actions associated with this CR. The CR documented the November 22, 2009, loss of all BOP AC power and resulting fires in the three BOP incoming switchgear breaker cubicles due to the failure to remove personnel protection ground devices from the switchgear prior to energizing the transformer. The NRC previously documented a NCV in Integrated Inspection Report 05000395/20100003 regarding the failure to properly control grounding equipment that resulted in the event. The corrective action weakness identified during review of CR-09-05093 involved the inadvertent closure of Action #2 which was to perform in the next 5 to 6 years, an Electric Power Research Institute (EPRI) recommended follow-up visual tactile examination of the jacket on the electrical cable above the switchgear that was not replaced, however, had been in the arc flash zone in order to assess potential hardening of the cable jacket. Due to an apparent misunderstanding regarding the origin and intent of this action, the electrical maintenance personnel who were assigned this action, closed it based on the completion of the original switchgear repairs conducted in November 2009. Since this was the only formal tracking mechanism for completing the EPRI recommendation, the inspectors believed that there was a good probability that this examination would have been missed. The licensee initiated CR-10-02930 and CR-10-03043 to address this issue which included plans to create new action requirements to schedule the cable examinations at the EPRI recommended timeframe. Based on subsequent clarification from EPRI on the basis for the recommended examination, it was determined that had the examinations not been performed there would have been no actual safety consequence. Specifically, subsequent age related hardening of the cable jacket, even if it were to occur, would not result in any cable reliability concerns since the core cable insulation had been undamaged from the fire event. Based on this, the inspectors determined that the human error in closing the CR action item was of minor significance.
4OA3 Event Followup
(Closed) LER 05000395/2010001-00: Reactor Building Cooling Units Reduced Air Flow Below Technical Specification Limits The inspectors reviewed the subject LER and applicable condition reports (CR-09-05126 and CR-10-01783) associated with the issue to verify the LER accuracy and appropriateness of the specified corrective actions. The cause of this event was the use of a non-conservative filtration area factor for calculation of the reactor building cooling unit (RBCU) air flow rate resulting in air flow rates slightly below the TS range between Refuel 16 and 18. The licensee replaced the filters and corrected the filtration area factor prior to the end of the Refuel 18. The enforcement aspects of this finding are
discussed in Section 4OA7. No other findings of significance were identified. This LER is closed.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings were identified.
.2 (Closed) Temporary Instruction (TI) 2515/179 Verification of Licensee Responses to
NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)
a. Inspection Scope
The inspectors performed the TI concurrent with IP 71124.01 Radiation Hazard
Analysis.
The inspectors reviewed the licensees source inventory records and identified the sources that met the criteria for reporting to the NSTS. The inspectors visually identified the sources contained in various calibration systems and verified the presence of the source by direct radiation measurement using a calibrated portable radiation detection survey instrument. The inspectors reviewed the physical condition of the irradiation devices to include documented source leak checks as appropriate. The inspectors reviewed the licensees procedures for source receipt, maintenance, transfer, reporting and disposal. The inspectors reviewed documentation that was used to report the sources to the NSTS. Documents reviewed are listed in sections 2RS1 of the attachment.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
.1 Quarterly Resident Inspector Exit Meeting
On October 14, 2010, the resident inspectors presented the integrated inspection results to Mr. Thomas Gatlin and other members of the licensee staff. The licensee acknowledged the results of these inspections. The inspectors confirmed that inspection activities discussed in this report did not contain proprietary material.
.2 Triennial Heat Sink Performance Inspection Exit Meeting
An exit meeting was conducted on August 6, 2010, to discuss the findings of this inspection. The inspectors confirmed that no proprietary information was retained during this inspection.
.3 Annual Public and Occupational Radiation Safety Inspection Exit Meeting
An exit meeting was conducted on August 20, 2010, to discuss the findings of this inspection. The inspectors confirmed that no proprietary information was retained during this inspection.
.4 Biennial Licensed Operator Requalification Inspection Exit Meeting
An exit meeting was conducted on August 26, 2010, to discuss the findings of this inspection. The inspectors confirmed that no proprietary information was retained during this inspection.
.5 Triennial Permanent Plant Modification/10CFR50.59 Inspection Exit Meeting
An exit meeting was conducted on August 27, 2010, to discuss the findings of this inspection. The inspectors confirmed that no proprietary information was retained during this inspection.
.6 Annual Emergency Preparedness Inspection Exit Meeting
An exit meeting was conducted on September 16, 2010, to discuss the findings of this inspection. The inspectors confirmed that no proprietary information was retained during this inspection.
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.
- TS 3.6.2.3, Reactor Building Cooling System, and TS 3.6.3, Particulate Iodine Cleanup System, requires, in part, that two independent groups of RBCUs and their associated high efficiency particulate air (HEPA) filter banks shall be operable in
Modes 1-4. Contrary to this, due to the use of a non-conservative HEPA filter filtration area factor in the calculation of air flow rates, on April 28, 2010, the licensee identified that RBCUs XAA0001A and XAA0002A had air flow rates slightly below the TS range required for operability between Refuel 16 and 18, and RBCUs XAA0001B and XAA0002B had air flow rates slightly below the TS range for operability between Refuel 16 and 17. The violation was determined to be of very low safety significance because the RBCUs remained capable of performing their design functions with the slight reduction in air flow rates. The licensee replaced the filters and corrected the filtration area factor prior to the end of Refuel 18. The licensee addressed this issue in their corrective action program as CR-09-05126 and CR-10-01783.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Archie, Senior Vice President, Nuclear Operations
- A. Barbee, Director, Nuclear Training
- L. Bennett, Manager, Plant Support Engineering
- L. Blue, Manager, Nuclear Training
- M. Browne, Manager, Quality Systems
- M. Coleman, Manager, Health Physics and Safety Services
- G. Douglass, Manager, Nuclear Protection Services
- M. Fowlkes, General Manager, Engineering Services
- D. Gatlin, Vice President, Nuclear Operations
- R. Haselden, General Manager, Organizational / Development Effectiveness
- R. Justice, Manager, Nuclear Operations
- G. Lippard, General Manager, Nuclear Plant Operations
- M. Mosley, Manager, Chemistry Services
- D. Shue, Manager, Maintenance Services
- W. Stuart, Manager, Design Engineering
- B. Thompson, Manager, Nuclear Licensing
- R. Williamson, Manager, Emergency Planning
- S. Zarandi, General Manager, Nuclear Support Services
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000395/2010004-01 VIO Failure to Notify the Commission of a Change in Medical Status (Section 1R11.2)
Closed
- 05000395/2010001-00 LER Reactor Building Cooling Units Reduced Air Flow Below TS Limits (Section 4OA3.1)
- 05000395/2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)
(Section 4OA5.2)