IR 05000220/2010004

IR 05000220-10-004, 05000410-10-04, 07/01/2010-09/30/2010, Nine Mile Point Nuclear Station, Units 1 and 2, Occupational/Public Radiation Safety

ML103060007
Person / Time
Site:	Nine Mile Point
Issue date:	11/02/2010
From:	Glenn Dentel Reactor Projects Branch 1
To:	Belcher S Nine Mile Point
Dentel, G RGN-I/DRP/BR1/610-337-5233
References
IR-10-004
Download: ML103060007 (35)

Text

ber 2, 2010

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2010004 AND 05000410/2010004

Dear Mr. Belcher:

On September 30,2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on October 15,2010, with Mr. Thomas Lynch, Acting Vice President Nine Mile POint, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two self-revealing findings of very low safety significance (Green).

Neither of the findings was determined to involve violations of NRC requirements. If you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at Nine Mile Point Nuclear Station.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-220,50-410 License Nos.: DPR-63, NPF-69

Enclosure:

Inspection Report 05000220/2010004 and 05000410/2010004 w/Attachment: Supplemental Information

REGION I==

Docket No.: 50-220,50-410 License No.: DPR-63, NPF-69 Report No.: 05000220/2010004; 05000410/2010004 Licensee: Nine Mile Point Nuclear Station, LLC (NMPNS)

Facility: Nine Mile Point, Units 1 and 2 Location: Oswego, NY Dates: July 1 through Sept~mber 30, 2010 Inspectors: K. Kolaczyk. Senior Resident Inspector E. Knutson, Senior Resident Inspector D. Dempsey, Resident Inspector N. Perry, Senior Project Engineer S. Schaffer, Senior Resident Inspector S. Barr, Senior Emergency Preparedness SpeCialist J. Furia, Senior Health Physicist S. Sloan, Reactor Engineer B. Haagensen, Resident Inspector Approved By: Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000220/2010004,05000410/2010004; 07/01/2010 ~ 09/30/2010; Nine Mile Point Nuclear

Station, Units 1 and 2; Occupational/Public Radiation Safety.

The report covered a three~month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Two Green findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process (SOP)." The cross-cutting aspects for the findings were determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Occupational/Public Radiation Safety

Green.

A self-revealing finding of very low safety significance was identified due to Nine Mile Point Nuclear Station (NMPNS) having unplanned, unintended occupational collective dose resulting from deficiencies in "as low as is reasonably achievable" (ALARA) planning and work control while performing the removal of steam condensing mode piping and components associated with the Unit 2 residual heat removal (RHR) system. Specifically.

NMPNS failed to properly plan and coordinate outage work. and failed to perform welding activities correctly. This resulted in expansion of the collective exposure for this work from 8.557 person-rem to 17.968 person-rem. NMPNS entered this issue into their corrective action program (CAP) as condition report (CR) 2010-8443.

The finding was more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.

Additionally, the finding was similar to example 6.i in Appendix E of Inspection Manual Chapter (IMC) 0612, in that it resulted in collective exposure of greater than 5 person-rem and exceeded the outage goal by greater than 50 percent. The finding was evaluated in accordance with IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," and was determined to be of very low safety significance because NMPNS's current three year rolling average collective dose is 144.781 person-rem, less than 240 person-rem per unit. The finding had a cross-cutting aspect in the area of human performance, work control, in that the outage plan did not adequately incorporate actions to address the impact of work on different job activities (H.3.b per IMe 0310). (Section 2RS2)

Green.

A self-revealing finding of very low safety significance was identified due to Nine Mile Point Nuclear Station (NMPNS) having unplanned, unintended occupational collective dose resulting from deficiencies in "as low as is reasonably achievable" (ALARA) planning and.work control while performing refueling floor activities at Unit 2. Specifically, the failure to have cleaned up a crud burst that had occurred late in the previous refueling outage, the decision to flood up the refueling cavity while refueling water activity remained four times higher than planned. incorrect calculations during reactor vessel (RV) head stud tensioning that resulted in having to remove the RV head insulation package and re-tension the RV head, and the inability to control work crew size on the refueling floor, resulted in expansion of the collective exposure for this work from 19.810 person-rem to 38.222 person-rem.

NMPNS entered this issue into their corrective action program (CAP) as condition report (CR) 2010-8444.

The finding was more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.

Additionally. the finding was similar to example 6.i in Appendix E of Inspection Manual Chapter (IMC) 0612, in that it resulted in collective exposure of greater than 5 person-rem and exceeded the outage goal by greater than 50 percent. The finding was evaluated in accordance with IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," and was determined to be of very low safety significance because NMPNS's current three year rolling average collective dose is 144.781 person-rem, less than 240 person-rem per unit. The finding had a cross-cutting aspect in the area of human performance, work control, in that the job site conditions which impacted human performance were not adequately incorporated into the outage plan (H.3.a per IMC 0310).

(Section 2RS2)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Nine Mile Point Unit 1 began the inspection period at full rated thermal power (RTP). On August 3, a technical specification-required shutdown was commenced due to an emergent equipment issue with the 102 emergency diesel generator (EDG). Power was reduced to 92 percent when the equipment problem was resolved and power was then restored to full RTP. On September 11, power was reduced to 70 percent to perform turbine stop valve (TSV) testing, during which, one of the valves failed shut. Following troubleshooting and repair, power was restored to full RTP on September 22 and remained there for the rest of the inspection period.

Nine Mile Point Unit 2 operated throughout the inspection period at full RTP.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Partial System Walkdown (71111.040 - Four samples)

a. Inspection Scope

The inspectors performed partial system walkdowns to verify risk-significant systems were properly aligned for operation. The inspectors verified the operability and alignment of these risk-significant systems while their redundant trains or systems were inoperable or out of service for maintenance. The inspectors compared system lineups to system operating procedures, system drawings, and the applicable chapters in the updated final safety analysis report (UFSAR). The inspectors verified the operability of critical system components by observing component material condition during the system walkdown.

The following plant system alignments were reviewed:

• Unit 1 offsite power system during a period of increased risk. due to unusually hot weather throughout the region;

• Unit 1 containment spray systems 112 and 122 due to increased risk significance while containment spray system 121 was inoperable during maintenance;

• Unit 2 offsite power system during a period of increased risk due to unusually hot weather throughout the region; and

• Unit 2 reactor core isolation cooling (RCIC) system following the completion of planned maintenance.

b. Findings

1\10 findings were identified.

.2 Complete System Walkdown (71111.04S - Two samples)

a. Inspection Scope

The inspectors performed complete walkdowns of the Unit 1 emergency condenser system and the Unit 2 high pressure core spray (HPCS) system to identify discrepancies between the existing equipment configuration and that specified in the design documents. Durjng the walkdowns, system drawings and operating procedures were used to determine the proper equipment alignment and operational status. The inspectors reviewed the open maintenance work orders (WOs) that could affect the ability of the systems to perform their functions. Documentation associated with temporary modifications, operator workarounds, and items tracked by plant engineering were also reviewed to assess their collective impact on system operation. In addition, the inspectors reviewed the condition report (CR) database to verify that equipment alignment problems were being identified and appropriately resolved.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours (71111.050 - Six samples)

a. Inspection Scope

The inspectors toured areas important to reactor safety to evaluate the station's control of transient combustibles and ignition sources, and to examine the material condition, operational status, and operational lineup of fire protection systems including detection, suppression. and fire barriers. The inspectors evaluated fire protection attributes using the criteria contained in Unit 1 UFSAR Appendix 10A, "Fire Hazards Analysis," Unit 2 UFSAR Appendix 98, "Safe Shutdown Evaluation," and the applicable pre-fire plans.

The areas inspected included:

• Unit 1 containment spray 12 corner room, reactor building 198,218, and 237 foot elevations (fire area FA2);

• Unit 1 diesel fire pump room (fire area 14);

• Unit 1 screen house (fire area 13);

• Unit 2 Division 1 EDG room (fire area 28);

• Unit 2 Division 2 EDG room (fire area 29); and

• Unit 2 Division 3 EDG room (fire area 30).

b. Findings

No findings were identified.

.2 Annual Inspection (71111.05A - One sample)

a. Inspection Scope

The inspectors completed one annual fire drill observation inspection sample. The inspectors observed an announced fire brigade drill on July 6, 2010, in the Unit 1 EDG 102 room. The inspectors observed brigade performance during the drill to evaluate donning and use of protective equipment and self-contained breathing apparatus, fire brigade leader command and control, fire brigade response time, communications, and the use of pre-fire plans. The inspectors attended the post-drill critique and reviewed the disposition of issues and deficiencies identified during the drill. The inspectors evaluated NMPNS's performance against the requirements contained in NMP-TR-1.01-107, "Nuclear Fire Brigade Training Program," Revision 00800.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06 - Two samples)

a. Inspection Scope

The inspectors reviewed the internal flood protection measures for equipment in the Unit 1 screen house and the Unit 2 emergency switchgear rooms. The inspectors evaluated NMPNS's protection of safety-related systems from internal flooding conditions. The inspectors performed a walkdown of the area, interviewed the system and probabilistic risk assessment (PRA) engineer, reviewed the internal flooding evaluation, and verified that equipment and conditions remained consistent with those indicated in the design baSis and flooding evaluation documents.

b. Findings

No findings were identified.

1

R07 Heat Sink Performance

.1 Annual Heat Sink Performance (71111.07A - One sample)

a. Inspection Scope

The inspectors reviewed Unit 2 'A' and 'B' residual heat removal (RHR) system heat exchanger performance testing in accordance with N2-TIP-RHS-4Y003, "Residual Heat Removal System Heat Exchanger (2RHS*E1 A and 2RHS*E1 B) Performance Monitoring (Suppression Pool Cooling Mode)," Revision 01. The inspectors reviewed the test results to verify that system performance was consistent with the design basis as specified in the UFSAR.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review (71111.110 - Two samples)

a. Inspection Scope

The inspectors evaluated two simulator scenarios in the licensed operator requalification training (LORT) program. The inspectors assessed the clarity and effectiveness of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operations, and the oversight and direction provided by the shift manager. During the scenarios, the inspectors also compared simulator performance with actual plant performance in the control room. The following scenarios were observed:

• On September 7,2010, the inspectors observed Unit 1 LORT to assess operator and of instructor performance during a scenario involving a loss 115 kilovolt (kV) power with failure of EDG 102 to start, trip of reactor recirculation pump 13, turbine building closed loop cooling system temperature control valve failure, trip of reactor feedwater pump 13 and resultant reactor scram, loss of reactor building ventilation, and a loss of EDG 103. The inspectors evaluated the performance of risk significant operator actions including the use of special operating procedures (SOPs) and emergency operating procedures (EOPs).

• On September 7,2010, the inspectors observed Unit 2 LORT to assess operator and instructor performance during a scenario involving a loss of the 'A' instrument air compressor, outward drift of a control rod, spurious actuation of the HPCS system, loss of off-site power with failure of an EDG to start, a reactor scram, and failure of one safety relief valve to close. The inspectors evaluated the performance of risk significant operator actions including the use of SOPs and EOPs.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.120 - Six samples)

a. InsQection Scope The inspectors reviewed performance-based problems, and the performance and condition history of selected systems and structures to assess the effectiveness of the maintenance program. The inspectors reviewed the systems to ensure that the station's review focused on proper maintenance rule scoping in accordance with Title 10, Code of Federal Regulations (10 CFR) Part 50.65, characterization of reliability issues, tracking system and component unavailability, and 10 CFR Part 50.65(a)(1) and (a)(2)classification. In addition, the inspectors reviewed the site's ability to identify and address common cause failures, and to trend key parameters. The following maintenance rule inspection samples were reviewed:

• Unit 1 containment spray system;

• Unit 1 structure monitoring program;

• Unit 1 site transformer maintenance program;

• Unit 1 emergency condenser system;

• Unit 2 structure monitoring program; and

• Unit 2 site transformer maintenance program.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Eight samples)

a. Inspection Scope

The inspectors evaluated the effectiveness of the maintenance risk assessments required by 10 CFR Part 50.65(a)(4). The inspectors reviewed equipment logs, work schedules, and performed plant tours to verify that actual plant configuration matched the assessed configuration. Additionally, the inspectors verified that risk management actions for both planned and emergent work were consistent with those described in station procedures. The inspectors reviewed risk assessments for the activities listed below.

• On August 3, an unplanned technical specification (TS) directed plant shutdown due to failure of the EDG 102 circulating oil pump, coincident with planned maintenance on 11 liquid poison pump that caused the pump to be inoperable.

• Week of August 9, that included planned maintenance on containment spray pump 121, instrument air compressor 12, 345 kV line 8 breaker R915, and emergent maintenance to correct a failure of reactor building closed loop cooling (RBCLC)pump 11 to start.

• On August 30, emergent maintenance to correct a failure of liquid pOison pump 11 during a monthly operability test.

• Week of September 15, that involved the opening of TSV-13 following its unplanned closure on September 11.

• Week of July 4, that included planned maintenance on the 'A' service water (SW)pump, 'B' RHR system quarterly surveillance, and the selective restriction of maintenance activities due to unusually hot weather for the northeastern United States that resulted in high load on the transmission grid for New York state.

• Week of August 8, that included planned maintenance and surveillance activities on the RCIC system.

• Week of August 16, that included emergent maintenance on the 'C' instrument air compressor while the 'B' instrument air compressor was unavailable due to planned maintenance.

• On August 24, emergent maintenance on the Division 3 EDG to replace a failed kiene (compression test) valve.

b. Findings

No findings were identified.

1 R 15 Operability Evaluations (71111.15 - Eight samples)

a. Inspection Scope

The inspectors evaluated the acceptability of operability evaluations, the use and control of compensatory measures, and compliance with TS. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, "Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, 'Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability"" and Inspection Manual Part 9900, "Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." The inspectors' reviews included verification that the operability determinations were made as specified by Procedure CNG-OP-1.01-1002, "Conduct of Operability Determinations I Functionality Assessments," Revision 00101. The technical adequacy of the determinations was reviewed and compared to the TSs, UFSAR, and associated design basis documents (DBDs). The following evaluations were reviewed:

• CR 2010-7900 concerning a trip of Unit 1 EDG 102 circulating oil pump;

• CR 2010-7992 concerning a through wall leak on Unit 1 SW piping at valve 72-443, RBCLC operating vent line;

• CR-2010-8834 concerning Unit 1 liquid poison pump 11 failure to achieve the TS required minimum flow rate during surveillance testing;

• CR 2010-7749 concerning failure of Unit 2 Division 1 emergency switchgear undervoltage relay 27AC-2ENSA24 to reset following a HPCS pump start;

• CR 2010-7940 concerning degraded Unit 2 standby gas treatment system filter discharge valve 2GTS*AOV3B;

• CR-2010-8334, concerning a trip of Unit 2 Division 2 EDG direct current control power circuit breaker 72DC3;

• CR-2010-8371 concerning the Unit 2 RCIC flow controller indicating 130 gallons per minute under no flow conditions; and

• CR-2010-8633 concerning a Unit 2 Division 3 EDG kiene (compression test) valve stem ejection.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Modifications (Two samples)

a. Inspection Scope

The inspectors reviewed Unit 2 temporary plant modification engineering change package (ECP) ECP-10-000439. "Support Reliable Service of 2VBB-UPS1A and 1B due to Heat Related Issues due to Age." The purpose of this change was to provide additional cooling to safety class inverters 2VBB-UPS 1A and 1B to reduce the frequency of age-related component failures. Both inverters recently were placed in (a)(1) status under 10 CFR Part 50.65 (the Maintenance Rule). These inverters are currently scheduled to be replaced in 2012. The inspectors also reviewed Unit 2 ECP-10-000721 which modified the electrical control circuit of a sixth point feedwater heater. The temporary modification was designed to prevent a feed system/reactor power transient by removing the high level dump control for valve 2HDH-LV26C and the automatic isolation of separator reheater drain tank inlet valve 2DSR-LV65A1B to the sixth point feedwater heaters. The inspectors interviewed system engineers, reviewed the applicable design documentation and 10 CFR Part 50.59 screenings against system design basis information, verified that post-installation tests were adequate, and verified that NMPNS controlled the modifications in accordance with station procedures.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19 - Seven samples)

a. Inspection Scope

The inspectors reviewed the post maintenance tests (PMTs) listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or DBDs, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed 1est data, to verify the test results adequately demonstrated restoration of the affected safety functions.

• Unit 1, WO C090624700 to replace the air actuator on emergency condenser steam line drain valve IV-39-11 R. The PMT included a local leakage rate test, performed in accordance with N1-ISP-LRT-TYC, "Type "C" Containment Isolation Valve Leak Rate Test," Revision 02001, and a stroke timing test, performed in accordance with N1-ST 04, "Reactor Coolant System Isolation Valves Operability Test," Revision 00500.

• Unit 1, WO C90693003 to perform preventive maintenance on the supply circuit breaker for liquid poison pump 12. The PMT was to demonstrate breaker operability in accordance with N1-ST-Q86, "Liquid Poison Pump 12 and Check Valve Operability Test," Revision 00100.

• Unit 1, WO C90840257 to replace directional control solenoid valve DCV-122 on control rod drive system hydraulic control unit 14-27. The PMTwas to perform a control rod stroke time test in accordance with N1-REP-25, "Control Rod Stroke Timing and Adjustment During Power Operations," Revision 00400.

• Unit 1, WO C90696522 to overhaul the diesel fire pump engine. The PMT was to verify fire pump capacity in accordance with N1-PM-C3, "Electric and Diesel Fire Pump Performance Tests," Revision 01200.

• Unit 1 WOs C90658477, C90802761 and C90658492 to perform core spray pump supply breaker maintenance and aging management inspection of the motor oil cooler. The PMT was to demonstrate proper motor cooler and breaker operation using N1-ST-016, "CS [core spray] 121 Pump, Valve and SDC [shutdown cooling]

Water Seal Check Valve Operability Test," Revision 01100.

• Unit 2, WO C90911841 to replace the 'A' SW pump. The PMTwas to demonstrate acceptable pump operation and to establish new in service test acceptance criteria in accordance with N2-0SP-SWP-Q002, "Service Water Pump and Valve Operability Test," Revision 01100, and N2-0SP-SWP-@001, "Service Water Pump Curve Validation Test," Revision 04.

• Unit 2, WO C90957689 to troubleshoot Division I undervoltage relay 27AC-2ENSA24.

The PMT was to demonstrate the correct setpoint and verify repeatability in accordance with N2-ESP-ENS-R733, "Operating Cycle Calibration For Loss and Degraded Voltage Relays on Emergency Switchgear 2ENS*SWG1 01," Revision 00900.

b. Findings

No findings were identified.

"R22 Surveillance Testing (71111.22 - Seven samples)

a. Inspection Scope

The inspectors witnessed performance of and/or reviewed test data for risk-significant surveillance tests (STs) to assess whether the components and systems tested satisfied design and licensing basis requirements. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness and were consistent with the DBDs; that test instrumentation had current calibrations and the range and accuracy for the application; and that tests were performed, as written, with applicable prerequisites satisfied. Upon test completion, the inspectors verified that equipment was returned to the status specified to perform its safety function.

The following STs were reviewed:

• N1-ST-Q16B, "Emergency Diesel Generator 103 Quarterly Test," Revision 00400;

• N1-ST-Q13, "Emergency Service Water Pump Operability Test," Revision 01200;

• N1-ST-SO, "Shift Checks," Revision 02300;

• N2-0SP-HVR-Q002, "Reactor Building Ventilation System Automatic Isolation Damper Operability Test," Revision 00301;

• N1-ST-Q1D, "CS 122 Pump and Valve Operability Test," Revision OOSOO;

• N1-ST-Q2S, "Emergency Diesel Generator Cooling Water Quarterly Test," Revision 01S01;and

• N1-ST-Q6B, "Containment Spray System Loop 121 Quarterly Operability Test,"

Revision 01000.

This represented a total of seven inspection samples, of which five were Routine Surveillances and four were In-Service Testing, as defined by Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Evaluation (71114.02 - One sample)

a. Inspection Scope

An onsite review was conducted to assess the maintenance and testing of the NMPNS alert and notification system (ANS). During this inspection, the inspectors interviewed emergency preparedness (EP) staff responsible for implementation of the ANS testing and maintenance, and reviewed CRs pertaining to the ANS for causes, trends, and corrective actions. The inspectors reviewed the ANS procedures and the ANS design report to ensure NMPNS's compliance with design report commitments for system maintenance and testing. The Planning Standard, 10 CFR Part S0.47(b)(S), and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 - One sample)a.

Inspection Scoge The inspectors conducted a review of NMPNS"s emergency response organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO. This was performed to ensure the readiness of key NMPNS staff to respond to an emergency event and to ensure NMPNS's ability to activate their emergency facilities in a timely manner. The inspectors reviewed the NMPNS ERO roster, training records, applicable procedures, drill reports for augmentation, quarterly EP drill reports, and CRs related to the ERO staffing augmentation system. The Planning Standard, 10 CFR Part 50.47(b)(2), and related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.

.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04 - One sample)a.

Insoection Scope Since the previous NRC inspection of this program area in September 2009, NMPNS had implemented various revisions of the different sections of the NMPNS Site Emergency Plan. NMPNS had determined that, in accordance with 10 CFR Part 50.54(q), any changes made to the Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR Part 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors reviewed all emergency action level (EAL) changes that had been made since September 2009, and conducted a sampling review of other Emergency Plan changes, including the changes to lower-tier emergency plan implementing procedures (EPIPs), to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in an NRC 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 requirements in 10 CFR Part 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

1EP5 Correction of Emergency Preparedness Weaknesses (71114.05 - One sample)

a. Inspection Scope

The inspectors reviewed a sampling of self-assessment procedures and reports to assess NMPNS's ability to evaluate and improve their EP performaRce and programs.

The inspectors reviewed a sample of drill reports, focused area self-assessment reports, 10 CFR Part 50.54(t) audits, and CRs initiated by NMPNS from January 2009 through June 2010. The Planning Standard, 10 CFR Part 50.47(b)(14), and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.

b. Findings

No findings were identified.

1EP6 Drill Evaluation (71114.06 - One sample)

a. Inspection Scope

On September 7, 2010. the inspectors observed a Unit 2 licensed operator simulator scenario that included a limited test of the NMPNS emergency response plan. The inspectors verified that emergency classification declarations and notifications were completed in accordance with 10 CFR Part 50.72. 10 CFR Part 50 Appendix E, and NMPNS emergency response procedures.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

The inspectors reviewed NMPNS's Performance Indicators (Pis) for the Occupational Exposure Cornerstone for follow-up. The inspectors reviewed the results of radiation protection program audits (e.g., NMPNS's quality assurance audits or other independent audits). The inspectors reviewed reports of operational occurrences related to occupational radiation safety since the last inspection.

Instructions to Workers:

The inspectors selected containers holding nonexempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers. and verified that they were labeled and controlled.

The inspectors reviewed radiation work permits (RWPs) used to access high radiation areas (HRAs) and to identify what work control instructions or control barriers had been specified. The inspectors verified that allowable stay times or permissible dose for radiologically significant work under each RWP was clearly identified. The inspectors verified that electronic personal dosimeter alarm set pOints were in conformance with survey indications and plant policy.

Contamination and Radioactive Material Control:

The inspectors observed several locations where NMPNS monitors potentially contaminated material leaving the radiological controlled area, and inspected the methods used for control, survey, and release of such materials from these areas. The inspectors verified that the radiation monitoring instrumentation had appropriate sensitivity for the types of radiation present.

The inspectors reviewed NMPNS's criteria for the survey and release of potentially contaminated material. The inspectors verified that there was guidance on how to respond to an alarm that indicated the presence of licensed radioactive material.

The inspectors reviewed NMPNS's procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters.

Risk-Significant HRA and Very High Radiation Area (VHRA)

Controls:

The inspectors discussed, with the radiation protection manager (RPM), the controls and procedures for high-risk HRAs and VHRAs. The inspectors verified that any changes to NMPNS procedures did not substantially reduce the effectiveness and level of worker protection.

The inspectors discussed, with first-line health physics supervisors, the controls in place for special areas that have the potential to become VHRAs during certain plant operations. The inspectors verified that NMPNS's controls for all VHRAs. and areas with the potential to become a VHRA, ensured that an individual is not able to gain unauthorized access to the VHRA.

Radiation Worker Performance:

During job performance observations, the inspectors observed radiation worker performance with respect to stated radiation protection work requirements. The inspectors verified that workers were aware of the significant radiological conditions in their workplace and the RWP controlsllimits in place, and that their performance reflected the level of radiological hazards present.

The inspectors reviewed radiological problem reports since the last inspection that had found the cause of the event to be human performance errors. The inspectors assessed whether there was no observable pattern traceable to a similar cause. The inspectors verified the corrective actions taken by NMPNS to resolve the reported problems were appropriate. The inspectors discussed, with the RPM, any problems with the corrective actions planned or taken.

b. Findings

No findings were identified.

,.

I

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

Verification of Dose Estimates and Exposure Tracking Systems:

The inspectors reviewed NMPNS's performance during the 2010 Unit 2 refueling outage (2RF012). In particular, the inspectors reviewed NMPNS's performance on two exposure significant jobs (greater than 5 person-rem), one involving a plant modification to retire components related to the steam condensing mode of the RHR system, and the second related to refueling floor activities.

The inspectors selected "as low as is reasonably achievable" (A LARA) work packages and reviewed the assumptions and basis for the current annual collective exposure estimate for reasonable accuracy. The inspectors reviewed the applicable procedures to determine the methodology for estimating exposures from specific work activities and the intended dose outcome.

The inspectors verified, for the selected work activities, that NMPNS established measures to track, trend, and if necessary, to reduce, occupational doses for ongoing work activities. The inspectors verified that trigger pOints or criteria were established to prompt additional reviews and/or additional ALARA planning and controls.

.1 Failure to Maintain Radiation Exposure ALARA During RHR System Modification

Introduction:

A self-revealing finding of very low safety Significance (Green) was identified due to NMPNS having unplanned. unintended occupational collective dose resulting from deficiencies in ALARA planning and work control while performing the removal of steam condensing mode piping and components associated with the Unit 2 RHR system (RWP/ALARA Review 210061). Specifically. NMPNS failed to properly plan and coordinate outage work, and failed to perform welding activities correctly.

During work on cuts 8A and 80, pre-outage planning and engineering design was inadequate, and four welds (4A. 4B, 4E, 80) had to be re-welded because they did not pass radiographic inspection. This resulted in expansion of the collective exposure for this work from 8.557 person-rem to 17.968 person-rem.

Description:

During 2RF012, NMPNS performed a plant modification to remove and/or isolate piping and components associated with the steam condensing mode of the Unit 2 RHR system. This modification involved the cutting and plugging of a number of pipes located on the 175, 196 and 215 foot elevations of the reactor building. At cut location 80. lack of proper work coordination led to significantly increased dose rates in the work area. Specifically, the nearby 'B' RHR heat exchanger was drained of shielding water to support another work activity (eddy current testing), which resulted in an additional 1.184 person-rem. At cut location 8A, lack of appropriate work planning resulted in significantly higher dose rates than expected; additionally, a number of unforeseen interferences which had to be removed led to increased work hours, resulting in an additional 7.939 person-rem. Following the welding of plugs on four pipes (4A, 4B, 4E, 80), radiographic examination identified weld deficiencies that required re-welding of the plugs, resulting in an additional 1.582 person**rem. As a result of these issues, the total collective dose for this activity expanded from its estimate of 8.557 person-rem to 17.968 person-rem. NMPNS entered this issue into their corrective action program (CAP) as CR 2010-8443.

Analysis:

The failure to appropriately plan and coordinate outage activities, together with the failure to properly weld four pipe plugs was a performance defiCiency that was within NMPNS's ability to control. The finding was more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Additionally, the finding was similar to example 6.i in Appendix E of Inspection Manual Chapter (IMC) 0612, in that it resulted in collective exposure of greater than 5 person-rem and exceeded the outage goal by greater than 50 percent. The finding is not subject to Traditional Enforcement because it did not affect the regulatory process or result in actual safety consequences. The inspectors evaluated the significance of this finding using IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process." The finding was determined to be of very low safety significance (Green) because NMPNS's current three year rolling average collective dose is 144.781 person-rem, less than 240 person-rem per unit. The finding had a cross-cutting aspect in the area of human performance, work control, in that the outage plan did not adequately incorporate actions to address the impact of work on different job activities (H.3.b per IMC 0310).

Enforcement:

No violation of regulatory requirements occurred. The ALARA rule (10 CFR Part 20.1101(b>> Statements of Consideration indicate that compliance with the ALARA requirement will be judged on whether the licensee has incorporated measures to track and, if necessary, to reduce exposures, and not whether exposures and doses represent an absolute minimum or whether the licensee has used all possible methods to reduce exposures. The overall exposure performance of a nuclear power plant is used to determine its compliance with the ALARA rule. NMPNS has entered this issue into their CAP as CR 2010-8443. Since NMPNS is below a three year rolling average of 240 person-rem per unit and has an established ALARA program to reduce exposure consistent with the 10 CFR Part 20.1101 Statements of Consideration, no violation of 10 CFR Part 20.1101(b) is considered. *Because this finding does not involve a violation and has very low safety significance it is identified as FIN 05000410/2010004-01, Failure to Maintain Radiation Exposure ALARA During RHR System Modification .

.2 Failure to Maintain Radiation Exposure ALARA During Refueling Floor Activities

Introduction:

A self-revealing finding of very low safety significance (Green) was identified due to NMPNS having unplanned, unintended occupational collective dose resulting from deficiencies in ALARA planning and work control while performing refueling floor activities at Unit 2 (RWP/ALARA Review 210890). NMPNS failed to properly perform several refueling floor activities correctly, and spent significantly more hours on the refueling floor than planned. Specifically, the failure to have cleaned up a crud burst that had occurred late in the previous refueling outage, the decision to flood up the refueling cavity while refueling water activity remained four times higher than planned, incorrect calcuJations during reactor vessel (RV) head stud tensioning that resulted in having to remove the RV head insulation package and re-tension the RV head, and the inability to control work crew size on the refueling floor, resulted in expansion of the collective exposure for this work from 19.810 person-rem to 38.222 person-rem.

Description:

During 2RF012, NMPNS Unit 2 refueling floor activities included reactor disassembly/reassembly, underwater testing and inspection, and refueling. These activities took place on the 353 foot elevation of the reactor building, in the reactor, reactor cavity, equipment storage pit, and spent fuel pool. During reactor disassembly, higher than normal contamination levels were encountered in the reactor cavity. This was due to a crud burst that had occurred near the end of the previous refueling outage (2RF011), and a decision that had been made at that time not to perform any significant cavity decontamination. As a result, during 2RF012, workers entering the cavity experienced higher than planned area dose rates, and required more robust anti contamination clothing and respiratory protection. This added an estimated 555 hours0.00642 days <br />0.154 hours <br />9.176587e-4 weeks <br />2.111775e-4 months <br /> of work for this activity, resulting in 2.304 person-rem of additional exposure.

On April 5, 2010, NMPNS decided to flood up the refueling cavity, although the refueling water contained concentrations of cobalt-60 that were four times higher than had been anticipated in the outage plan. Higher than planned effective dose rates were then encountered by workers near the cavity, resulting in 1.564 person-rem of additional exposure.

On April 25-26, 2010, NMPNS installed the RV head, tensioned the studs, and installed the RV head insulation package. It was then discovered that a calculation error had been made when verifying that the correct levels of stud tensioning had been achieved.

As a result, some of the RV head studs had to be re-tensioned. To accomplish this, the RV head insulation package had to be removed and later re-installed. This error resulted in 475 additional hours of work, and 5.15 person-rem of additional exposure.

The lack of positive controls over work crew size led to overall reassembly work (beyond the RV head stud issue) exceeding its estimates by 622 hours0.0072 days <br />0.173 hours <br />0.00103 weeks <br />2.36671e-4 months <br /> and 4.385 person-rem.

NMPNS did not take appropriate act(ons, either by work supervisors, the outage control center, or health physics to ensure that the number of workers for a given task was minimized. Thus, during reactor reassembly, large numbers of personnel having limited amounts of work to perform were permitted to remain on the refuel floor collecting radiation exposure unnecessarily. This expanded total work hours for all refueling activities from an estimated 12,952 hours0.011 days <br />0.264 hours <br />0.00157 weeks <br />3.62236e-4 months <br /> to 19,528 hours0.00611 days <br />0.147 hours <br />8.730159e-4 weeks <br />2.00904e-4 months <br />. As a result, total collective dose for the refueling floor activities expanded from its estimate of 19.810 person-rem to 38.222 person-rem. NMPNS entered this issue into their CAP as CR 2010-8444.

Analysis:

The failure to appropriately plan and control outage activities, together with a calculation error resulting in significant rework was a performance deficiency that was within NMPNS's ability to control. The finding was more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Additionally, the finding was similar to example 6.i in Appendix E of IMC 0612, in that it resulted in collective exposure of greater than 5 person-rem and exceeded the outage goal by greater than 50 percent. The finding is not subject to Traditional Enforcement because it did not affect the regulatory process or result in actual safety consequences. The inspectors evaluated the significance of this finding using IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process." The finding was determined to be of very low safety significance because NMPNS's current three year rolling average collective dose is 144.781 person-rem, less than 240 person-rem per unit. The finding had a cross-cutting aspect in the area of human performance, work control, in that the job site conditions which impacted human performance were not adequately incorporated into the outage plan (H.3.a per IMC 0310).

Enforcement:

No violation of regulatory requirements occurred. The ALARA rule (10 CFR Part 20.1101 (b>> Statements of Consideration indicate that compliance with the ALARA requirement will be judged on whether the licensee has incorporated measures to track and, if necessary, to reduce exposures, and not whether exposures and doses represent an absolute minimum or whether the licensee has used all possible methods to reduce exposures. The overall exposure performance of a nuclear power plant is used to determine its compliance with the ALARA rule. NMPNS has entered this issue into their CAP as CR 2010-8444. Since NMPNS is below a three year rolling average of 240 person-rem per unit and has an established ALARA program to reduce exposure consistent with the 10 CFR Part 20.1101 Statements of Consideration, no violation of 10 CFR Part 20.1101

(b) is conSidered. Because this finding does not involve a violation and has very low safety significance, it is identified as FIN 0500041012010004*02, Failure to Maintain Radiation Exposure ALARA During Refueling Floor Activities.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

Whole Body Counter The Inspectors reviewed the methods and sources used to perform whole body counter (WBC) functional checks before daily use of the instrument. The inspectors verified that check sources were appropriate and aligned with the plant's isotopic mix.

The inspectors reviewed WBC calibration reports completed since the last inspection to verify that calibration sources were representative of the plant source term and that appropriate calibration phantom sources were used.

b. Findings

No findings were identified.

OTHER ACTIVITIES

40A1 Performance Indicator Verification (71151 - Eight samples)

a. Inspection Scope

The inspectors sampled NMPNS submittals for the Pis listed below. The PI definition guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Indicator Guideline," Revision 6, was used to verify the basis in reporting for each data element and the accuracy of the PI data reported.

Cornerstone: Mitigating Systems

The inspectors reviewed NMPNS's submittals for the Mitigating System Performance Index (MSPI) listed below to determine the accuracy and completeness of the reported data. The review was accomplished by comparing the reported PI data to plant records and information available in plant logs, CRs, system health reports, the respective MSPI Basis Documents, and NRC inspection reports. Operating data for the period of July 2009 through June 2010 were reviewed to complete this inspection.

• Unit 1 emergency alternating current power system;

• Unit 1 high pressure injection system;

• Unit 1 heat removal system;

• Unit 1 RHR system; and

• Unit 1 cooling water systems.

Cornerstone: Emergency Preparedness

The inspectors reviewed data for the NMPNS EP Pis, which are:

(1) Drill and Exercise Performance (DEP):

(2) ERO Drill Participation; and

(3) ANS. The inspectors reviewed supporting documentation from EP drills, training records, and equipment tests from the third calendar quarter of 2009 through the second quarter of 2010, to verify the accuracy of the reported PI data. The review of these Pis was conducted using the acceptance criteria documented in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 6.

b. Findings

No findings were identified.

40A2 Problem Identification and Resolution (71152)

.1 Review of Items Entered into the CAP

a. Inspection Scope

As specified 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 review of items entered into NMPNS's CAP. In accordance with the baseline inspection procedures, the inspectors also identified selected CAP items across the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for additional follow-up and review. The inspectors assessed the threshold for problem identification, the adequacy of the cause analyses, extent of condition review, operability determinations, and the timeliness of the specified corrective actions.

b. Findings

No findings were identified .

.2 Annual Sample - Unit 1 Susceptibility of 115 KV Offsite Power to Lightning Strikes

(One sample)

a. Inspection Scope

The inspectors reviewed NMPNS's evaluations and corrective actions associated with the Unit 1 115 kV offsite transmission line's susceptibility to loss of the line due to lightning strikes. The inspectors interviewed operations personnel and the system engineer to ensure that the issue was completely understood. The inspectors reviewed related CRs, and causal evaluations to ensure that the full extent of the issues was identified, evaluations were performed, and appropriate corrective actions were identified and completed.

b. Findings

No findings were identified.

40A6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. Thomas Lynch and other members of licensee management at the conclusion of the inspection on October 15, 2010. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Belcher, Vice President

T. Lynch, Plant General Manager

P. Bartolini, Supervisor, Design Engineering

J. Dean, Director Nuclear Oversight

R. Dean, Training Manager

S. Dhar, Design Engineering

J. Dosa, Director, Licensing

J. Holton, Supervisor, Systems Engineering

J. Kaminski, Director, Emergency Preparedness

J. Krakuszeski, Manager, Operations

T. Kulczycky, Principle Engineer

M. Kunzwiler, Security Supervisor and Fatigue Rule Program Coordinator

J. Moody, Consultant

F. Payne, Unit 1 General Supervisor Operations

M. Shanbhag, Licensing Engineer

S. Sova, Radiation Protection Manager

H. Strahley, Unit 2 General Supervisor Operations

T. Syrell, Manager, Nuclear Safety and Security

J. Vaughn, Operations Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Opened and Closed

05000410/2010004-01 FIN Failure to Maintain Radiation Exposure ALARA During RHR System Modification (Section 2RS2)

05000410/2010004-02 FIN Failure to Maintain Radiation Exposure ALARA During Refueling Floor Activities (Section 2RS2)

Discussed

None.