IR 05000220/2016003
| ML16308A073 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/03/2016 |
| From: | Anthony Dimitriadis Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2016003 | |
| Download: ML16308A073 (42) | |
Text
November 3, 2016
SUBJECT:
NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2016003 AND 05000410/2016003
Dear Mr. Hanson:
On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. On October 6, 2016, the NRC inspectors discussed the results of this inspection with Mr. Robert Kreider, Plant General Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection. However, inspectors documented a licensee-identified violation which was determined to be of very low safety significance (Green) in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspectors at Nine Mile Point Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69
Enclosure:
Inspection Report 05000220/2016003 and 05000410/2016003 w/Attachment: Supplementary Information
REGION I==
Docket Nos.
50-220 and 50-410
License Nos.
Report Nos.
05000220/2016003 and 05000410/2016003
Licensee:
Exelon Generation Company, LLC (Exelon)
Facility:
Nine Mile Point Nuclear Station, LLC (NMPNS)
Units 1 and 2
Location:
Oswego, New York
Dates:
July 1, 2016, through September 30, 2016
Inspectors:
K. Kolaczyk, Senior Resident Inspector
E. Miller, Resident Inspector
G. Stock, Resident Inspector
J. DeBoer, Emergency Preparedness Specialist
J. Furia, Senior Health Physicist
P. Kaufman, Senior Reactor Inspector
M. Phalen, Senior Health Physicist
R. Rolph, Health Physicist
Approved by:
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects
SUMMARY
Inspection Report 05000220/2016003 and 05000410/2016003; 07/01/2016 - 09/30/2016; Nine
Mile Point Nuclear Station, Units 1 and 2; Integrated Inspection Report.
This report covered a three month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
Other Findings
A violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On July 29, 2016, operators reduced power to 90 percent when a turbine bypass valve opened while operators were increasing reactor power following an unplanned isolation of the reactor water cleanup system. Operators restored power to 100 percent the same day. On August 13, operators reduced power to 95 percent to perform a control rod pattern adjustment. Operators restored power to 100 percent the same day. Unit 1 remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power and remained at or near 100 percent power for the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Exelons readiness for the onset of unseasonably hot temperatures during the week of July 11, 2016. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the Unit 1 emergency diesel generator (EDG) 102 and EDG 103; screenhouse and turbine building elevations 261 and 305; and the Unit 2 Division I and Division II EDG rooms. The inspectors verified that operator actions defined in Exelons adverse weather procedures maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
==1R04 Equipment Alignment
==
.1 Partial System Walkdown
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
- Unit 2 residual heat removal (RHR) A system following RHR B system loose snubber discovery on July 15, 2016
- Unit 1 uninterruptible power supply (UPS) 162B while UPS 162A was in service supplying reactor protection system 11 on August 8, 2016
- Unit 2 Division II control building special filter ventilation system while Division I was out of service for planned maintenance on August 16, 2016
- Unit 2 Division I EDG while the Division ll EDG was out of service for planned maintenance during the week of September 26, 2016
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), work orders (WOs), action requests (ARs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to determine if system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On September 30, 2016, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 reactor building ventilation system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the Updated Final Safety Analysis Report (UFSAR) to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system to verify as-built system configuration matched plant documentation, and that system components and support equipment remained operable. The inspectors confirmed that the system and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related issue reports (IRs) and work orders (WOs) to ensure Exelon appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
==1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 6 samples)
a.
==
Inspection Scope
The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures. The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features.
- Unit 1 foam room (FA 4) on August 17, 2016
b. Findings
No findings were identified.
1R07 Heat Sink Performance
.1 Annual Review
a. Inspection Scope
The inspectors reviewed the Unit 2 Division I EDG jacket water heat exchangers (HXs)readiness and availability to perform their safety functions. The inspectors reviewed the design basis for the components and verified Exelons commitments to NRC Generic Letter (GL) 89-13, Service Water System Requirements Affecting Safety-Related Equipment. The inspectors observed an inspection of both EDG jacket water HXs during a planned maintenance period. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the HXs did not exceed the maximum amount allowed by the engineering analysis of record.
b. Findings
No findings were identified.
.2 Triennial Review
a. Inspection Scope
Heat Exchanger Sample Selection
The inspectors selected the following HX samples for this inspection based on Exelons risk ranking of safety-related HXs, past triennial heat sink inspections, recent operational experience, and resident inspectors input.
- Unit 2 RHR pump room coolers 2HVR*UC401A, B, and C
- Unit 2 low-pressure core spray (LPCS) pump room cooler 2HVR*UC402A
- Unit 2 high-pressure core spray (HPCS) pump room cooler 2HVR*UC403B
For the samples selected, the inspectors reviewed program/system health reports, self-assessments, and methods (inspection, cleaning, maintenance, and performance monitoring) used to ensure heat removal capabilities for the safety-related HX coolers and compared them to the NMPNS commitments made in response to GL 89-13. The HXs and coolers reviewed are monitored by means of performance testing and supplemented with cleaning and inspection. The area coolers reviewed are performance tested.
Heat Exchangers Directly Cooled by Service Water System
For the samples selected each of the HXs are directly cooled by the service water (SW)system. The inspectors reviewed the method and results of HX and cooler performance testing to verify performance. The inspectors reviewed the procedures and programs for maintaining the safety functions of the HXs and coolers that were monitored by means of performance testing, cleaning, inspection, and discussed the activities with station personnel.
The inspectors reviewed the results of performance tests, inspections and cleaning of the selected HXs and coolers, trending of tube plugging for the RHR HXs, and engineering calculations of tube plugging limits for the RHR HXs. The inspectors verified whether the test methodology was consistent with accepted industry practices (Electric Power Research Institute NP-7552, HX Performance Monitoring Guidelines)and compared completed test results to the established acceptance criteria to verify that the test conditions were consistent with the selected test methodology, test results were acceptable, test results considered test instrument inaccuracies, and operation was consistent with the plant design basis values.
The inspectors walked down accessible portions of HPCS, LPCS, SW, and RHR piping, pumps, valves, and HXs and coolers to assess the material condition of the components.
The inspectors reviewed the completed WOs and associated photos of the inspection and cleaning of the HXs and coolers to verify whether the as-found and as-left conditions were bound by assumptions in the engineering analyses and provided reasonable assurance of continued operability and had an adequate cooling margin.
Unit 2 Service Water System Review
The inspectors reviewed Unit 2 SW flow calculations and SW pump inservice test (IST)data to assess whether the minimum calculated flowrate, in conjunction with the heat transfer capability of the HXs and coolers, supported the minimum heat transfer rates assumed during accident and transient conditions described in the UFSAR.
The inspectors performed a walkdown of the intake structure and verified proper functioning of the trash rakes and traveling screens. The inspectors verified whether the intake bay silt accumulation was monitored and maintained at an acceptable level, and that level instruments were maintained functional and routinely monitored.
The inspectors reviewed the chemistry controls for the SW system and discussed the monitoring with a system engineer. The inspectors determined whether the chemical treatment programs for corrosion control and biotic control were consistent with industry standards. The inspectors verified that the testing, inspection, maintenance, and monitoring of biotic fouling and macrofouling programs were singularly or in combination adequate to ensure proper heat transfer.
Corrective Action Reports Review
The inspectors selected and reviewed a sample of CAP reports related to the heat sink and HX cooler samples chosen for this inspection. The inspectors determined whether Exelon staff were appropriately identifying, characterizing, and correcting problems related to these systems and components, and that the planned or completed corrective actions for the reported issues were appropriate.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training (2 samples)
a. Inspection Scope
The inspectors observed:
- Unit 1 licensed operator simulator training scenario on July 19, 2016, which involved performing an EDG monthly surveillance, a trip of motor generator 131, a failure of a control rod drive (CRD) flow control valve, a main steam line break inside containment with a failure of containment spray, and a low power anticipated transient without scram
- Unit 2 licensed operator simulator training scenario on August 10, 2016, which involved performing a condenser air removal pump bi-monthly surveillance, a trip of a CRD pump with low suction pressure, an initiation of Division I emergency core cooling systems with a minimum flow valve failure, a CSL*MOV104 breaker trip, an inadvertent safety relief valve opening, and an unisolable reactor core isolation cooling (RCIC) steam leak
The inspectors evaluated operator performance during the simulated event and verified completion of risk-significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the unit supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the technical specification (TS) action statements entered by the unit supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
(2 samples)
a. Inspection Scope
The inspectors observed:
- Unit 1 control room observations during adverse weather conditions and surveillance testing activities July 18 and 20, 2016
- Unit 2 control room observations during impending adverse weather conditions on July 18, 2016 The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Exelon procedure HU-AA-101, Human Performance Tools and Verification Practices, Revision 009. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of plant activities among work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff were identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
- Unit 2 structural monitoring program walkdown of the auxiliary boiler building and screenwell building roofs on July 27, 2016
- Unit 1 diesel driven fire pump repeated failure to start on August 26, 2016
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment from service. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
- Unit 1 EDG 102, power board 102, and EDG 102 raw water pump during planned containment spray 122 system maintenance window on July 12, 2016
- Unit 1 risk mitigation actions while unplanned maintenance was performed on instrument air compressor 12 during the week of August 1, 2016
- Unit 2 unplanned maintenance on the Division II EDG during a Yellow plant risk condition on August 3, 2016
- Unit 2 Yellow risk condition while the RCIC system was out of service for planned maintenance on August 10, 2016
- Unit 1 risk mitigation actions during planned 121 core spray relay functional testing on August 25, 2016
- Unit 2 risk mitigation actions during unplanned Division II EDG maintenance window and Yellow risk condition on August 29, 2016
- Unit 2 risk management actions during planned Division I EDG maintenance window on September 13, 2016
- Unit 2 risk management actions during planned Division II EDG maintenance window on September 28, 2016
- Unit 1 unplanned maintenance on BKR-(13A/004C)52 PB-131A feeder breaker at PB-13A on September 30, 2016
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on risk significance of the associated components and systems:
- Unit 2 RHR B following discovery of air void in drywell spray line on July 22, 2016
- Unit 2 review of the operator workaround (OWA) program completed August 17, 2016
- Unit 1 review of the OWA program completed August 18, 2016
The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Exelons evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, such as in the case of OWAs, the inspectors evaluated whether the measures in place would function as intended and were properly controlled by Exelon. Based on the review of the selected OWAs listed above, the inspectors verified that Exelon identified OWAs at an appropriate threshold and addressed them in a manner that effectively managed OWA-related effects on operators and SSCs.
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modification
a. Inspection Scope
The inspectors evaluated Unit 1 Engineering Change Package 15-000618, Deactivate Core Spray Pump 111 Pressure Relief Valve by Installing a Blind Coupling On the Inlet, Revision 0. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by this modification.
In addition, the inspectors reviewed modification documents associated with the design changes.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold point were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.
- Unit 1 drywell vent and purge valve 201-31 following preventive maintenance on July 6, 2016
- Unit 2 control room emergency filtration radiation monitor following sample pump refurbishment on July 6, 2016
- Unit 1 containment spray system 112 following HX maintenance on July 26, 2016
- Unit 1 control rod insert switch following replacement on July 27, 2016
- Unit 1 S-EPM-MPM-V080 offline motor testing on core spray pump 121 (MOT-81-03)on August 23, 2016
- Unit 2 Division II EDG following fuel rack maintenance on August 30, 2016
- Unit 1 EDG 102 fuel oil storage tank fuel oil sampling following bottom cleaning on September 8, 2016
- Unit 2 Division I diesel generator lube oil storage tank cleaning and inspection on September 13, 2016
- Unit 1 core spray system 112 following the disabling of the core spray pump relief valve on September 14, 2016
- Unit 2 Division I EDG run following planned maintenance on September 30, 2016
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
- Unit 1 N1-ST-Q8A, Liquid Poison Pump 11 and Check Valve Operability Test on July 18, 2016
- Unit 2 N2-ISP-ISC-Q005, Functional Test of the Reactor Vessel Level 2 and Level 1 Instrument Channels on July 22, 2016
- Unit 2 N2-OSP-LOG-W001, Weekly Checks on August 3, 2016
- Unit 1 N1-ST-Q13, Emergency Service Water Pump and Check Valve Operability Test on August 23, 2016
- Unit 1 N1-ST-Q16B, Emergency Diesel Generator 103 Quarterly Test on August 8, 2016 (IST)
- Unit 1 EDG 102 Raw Water Pump Surveillance Test on August 18, 2016
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
An onsite review was conducted to assess the performance, maintenance, and testing of NMPNSs alert and notification system (ANS). During this inspection, the inspectors conducted a review of the ANS testing and maintenance programs. The inspectors reviewed the associated ANS procedures and the Federal Emergency Management Agency-approved ANS design report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted utilizing 10 CFR 50.47(b)
- (5) and the related requirements of 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspectors conducted a review of the NMPNS emergency response organization (ERO) on-shift and augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to assess the readiness of key Exelon staff to respond to an emergency event and to verify Exelons ability to activate its emergency response facilities (ERF) in a timely manner. The inspectors reviewed NMPNS emergency plan for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, the most recent drive-in drill reports, and CAP reports related to this inspection area. The inspectors also reviewed a sample of ERO responder training records to determine training and qualifications were up to date. The inspection was conducted utilizing 10 CFR 50.47(b)(2) and related requirements of 10 CFR Part 50, Appendix E, as reference criteria.
b. Findings
One licensee-identified Green NCV of 10 CFR 50.54q(2) for Exelons failure to implement its NRC-approved emergency plan. Specifically, prior to the inspection, Exelon identified and documented in its CAP that it had not conducted required health physics drills as part of its emergency plan training for the second half of 2015 as required. The enforcement aspects of this NCV are discussed in section 4OA7.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspectors reviewed a number of activities to evaluate the efficacy of Exelons efforts to maintain its emergency preparedness program. The inspectors reviewed letters of agreement with offsite agencies, the 10 CFR 50.54(q) emergency plan change process and practice, Exelons maintenance of equipment important to emergency preparedness, records of evacuation time estimate population evaluation, and provisions for, and implementation of, primary and backup ERF maintenance. The inspectors also examined Exelons compliance with NRC emergency preparedness regulations regarding emergency action levels for hostile action events, protective actions for on-site personnel during events, emergency declaration timeliness, ERO augmentation and alternate facility capability, evacuation time estimate updates, and on-shift ERO staffing analysis.
The inspectors further evaluated Exelons ability to maintain its emergency preparedness program through identification and correction of weaknesses by reviewing a sample of drill reports, actual event reports, self-assessments, 10 CFR 50.54(t)reviews, and emergency preparedness-related issue reports. The inspectors reviewed a sample of emergency preparedness-related issue reports initiated from July 2014 through June 2016. The inspection was conducted utilizing 10 CFR 50.47(b) and the related requirements of 10 CFR Part 50, Appendix E, as reference criteria.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Unit 1 Exelon emergency drill on July 26, 2016, to identify any weaknesses and deficiencies in the classification, notification, and protection action recommendation development activities. The inspectors observed emergency response operations in the simulator and the emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelons critique and to verify whether the Exelon staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
.2 Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for Unit 1 licensed operators on July 19, 2016, which involved performing an EDG monthly surveillance, a trip of motor generator 131, a failure of a CRD flow control valve, and a main steam line break inside containment with a failure of containment spray and a low power anticipated transient without scram, which required emergency plan implementation by an operations crew.
Exelon planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Exelon evaluators noted the same issues and entered them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety and Occupational Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
(2 samples)
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR Part 20, Standards for Protection Against Radiation, regulatory guide (RG)8.15, Acceptable Programs For Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG/CR-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TS, and procedures required by TS as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring systems associated with airborne radioactivity controls and respiratory protection equipment staged for emergency use. The inspectors also reviewed respiratory protection program procedures and current performance indicators for unintended internal exposure incidents.
Self-Contained Breathing Apparatus for Emergency Use (1 sample)
The inspectors reviewed the status and surveillance records for three Self-Contained Breathing Apparatus (SCBAs) staged in-plant for use during emergencies Exelons SCBA procedures and maintenance and test records, the refilling and transporting of SCBA air bottles, SCBA mask size availability, and the qualifications of personnel performing service and repair of this equipment.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were identified at an appropriate threshold and addressed by Exelons CAP.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors reviewed the monitoring, assessment, and reporting of occupational dose. The inspectors used the requirements in 10 CFR Part 20, Regulatory Guides, TSs, and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed radiation protection program audits, National Voluntary Laboratory Accreditation Program (NVLAP) dosimetry testing reports, and procedures associated with dosimetry operations.
External Dosimetry (1 sample)
The inspectors reviewed dosimetry NVLAP accreditation, on-site storage of dosimeters, the use of correction factors to align electronic personal dosimeter results with NVLAP dosimetry results, dosimetry occurrence reports, and CAP documents for adverse trends related to external dosimetry.
Special Dosimetric Situations (1 sample)
The inspectors reviewed Exelons worker notification of the risks of radiation exposure to the embryo/fetus, the dosimetry monitoring program for declared pregnant workers, external dose monitoring of workers in large dose rate gradient environments, and dose assessments performed since the last inspection that used multi-badging, skin dose, or neutron dose assessments.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with occupational dose assessment were identified at an appropriate threshold and properly addressed in the CAP.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
(6 samples)
a. Inspection Scope
The inspectors reviewed the treatment, monitoring, and control of radioactive gaseous and liquid effluents. The inspectors used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix I, Numerical Guides For Design Objectives and Limiting Conditions For Operation to Meet the Criterion As Low As Is Reasonably Achievable For Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; technical specifications (TSs); Offsite Dose Calculation Manual (ODCM); applicable industry standards; and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors conducted in-office review of the Nine Mile Point 2014 and 2015 annual radioactive effluent and environmental reports, radioactive effluent program documents, updated final safety analysis report (UFSAR), ODCM, and applicable event reports.
Walk-downs and Observations (1 sample)
The inspectors walked down the gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design. The inspectors also observed potential unmonitored release points and reviewed radiation monitoring system surveillance records and the routine processing and discharge of gaseous and liquid radioactive wastes.
Calibration and Testing Program (1 sample)
The inspectors reviewed gaseous and liquid effluent monitor instrument calibration, functional test results, and alarm set-points based on National Institute of Standards and Technology calibration traceability and ODCM specifications.
Sampling and Analyses (1 sample)
The inspectors reviewed: radioactive effluent sampling activities, representative sampling requirements; compensatory measures taken during effluent discharges with inoperable effluent radiation monitoring instrumentation; the use of compensatory radioactive effluent sampling; and the results of the inter-laboratory and intra-laboratory comparison program including scaling of hard-to-detect isotopes.
Instrumentation and Equipment (1 sample)
The inspectors reviewed the methodology used to determine the radioactive effluent stack and ventilation flow rates to verify that the flow rates were consistent with TS/ODCM and UFSAR values. The inspectors reviewed radioactive effluent discharge system surveillance test results based on technical specification acceptance criteria.
The inspectors verified that high-range effluent monitors used in emergency operating procedures are calibrated and operable and reviewed post-accident effluent sampling capability.
Dose Calculations (1 sample)
The inspectors reviewed: changes in reported dose values from the previous annual radioactive effluent release reports; several liquid and gaseous radioactive waste discharge permits; the scaling method for hard-to-detect radionuclides; ODCM changes; land use census changes; public dose calculations (monthly, quarterly, annual); and records of abnormal gaseous or liquid radioactive releases.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with the radioactive effluent monitoring and control program were identified at an appropriate threshold and properly addressed in Exelons corrective action program.
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation (71124.08 - 5 samples)
a. Inspection Scope
The inspectors verified the effectiveness of Exelons programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 49 CFR 170-177; 10 CFR Part 20, 37, 61, and Part 71; applicable industry standards; regulatory guides; and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors conducted an in-office review of the solid radioactive waste system description in the UFSAR, the process control program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed. The inspectors reviewed the scope of quality assurance audits performed for this area since the last inspection.
Radioactive Material Storage (1 sample)
The inspectors walked down the following items and areas:
- Accessible portions of liquid and solid radioactive waste processing systems to verify current system alignment and material condition
- Abandoned in-place radioactive waste processing equipment to review the controls in place to ensure protection of personnel
- Changes made to the radioactive waste processing systems since the last inspection
- Processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers
- Current methods and procedures for dewatering radioactive waste.
Waste Characterization and Classification (1 sample)
The inspectors identified radioactive waste streams and reviewed radiochemical sample analysis results to support radioactive waste characterization. The inspectors reviewed the use of scaling factors and calculations to account for difficult-to-measure radionuclides.
Shipment Preparation (1 sample)
The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and Exelon verification of shipment readiness.
Shipping Records (1 sample)
The inspectors reviewed selected non-excepted package shipment records.
Problem Identification and Resolution (1 sample)
The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation were identified at an appropriate threshold and properly addressed in Exelons CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Emergency Preparedness (3 samples)
a. Inspection Scope
The inspectors reviewed Exelons data for the following three emergency preparedness performance indicators (PIs):
- Drill and Exercise Performance (EP01)
- ERO Drill Participation (EP02)
- Alert and Notification System Reliability (EP03)
The inspectors reviewed supporting documentation from emergency preparedness drills and equipment tests from the third calendar quarter of 2015 through the second calendar quarter of 2016 to verify the accuracy of the reported PI data. The last NRC emergency preparedness inspection was conducted in the third calendar quarter of 2015. Inspectors also used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed Exelons operator narrative logs, maintenance planning schedules, IRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index (12 samples)
a. Inspection Scope
The inspectors sampled Exelons submittal for the mitigating systems performance index for the following systems for the period of July 1, 2015, through June 30, 2016.
Unit 1 and Unit 2
- Safety System Function Failures (MS05)
- Emergency Alternating Current Power System (MS06)
- High Pressure Injection System (MS07)
- Heat Removal System (MS08)
- Residual Heat Removal System (MS09)
- Cooling Water System (MS10)
To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in NEI 99-02, and NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3. The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, IRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspectors reviewed Exelons submittals for the occupational radiological occurrences PIs for the first quarter 2015 through the fourth quarter 2015. The inspectors used PI definitions and guidance contained in NEI 99-02, Revision 7, to determine the accuracy of the PI data reported. The inspectors reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences. The inspectors conducted walkdowns of various locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.
b. Findings
No findings were identified.
.4 Radiological Effluent TS/ODCM Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
The inspectors reviewed licensee submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the first quarter 2015 through the fourth quarter 2015. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Revision 7, to determine if the PI data was reported properly.
The inspectors reviewed the public dose assessments for the PI for public radiation safety to determine if related data was accurately calculated and reported.
The inspectors reviewed the corrective action program database to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated offsite dose calculations to determine if indicator results were accurately reported.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify Exelon entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon performed an evaluation in accordance with 10 CFR Part 21.
b. Findings and Observations
No findings were identified.
.2 Annual Sample Review: Drill and Exercise Performance
a. Inspection Scope
The inspectors conducted an in depth review of Exelons evaluation of, and corrective actions for, the problems encountered in the latter part of 2014 and into the early part of 2015 in regards to the multiple drill and exercise performance (DEP) failures. On January 29, 2015, Exelon initiated issue report (IR) 02444424 to document seven DEP failures since January 2014. The failures ranged from classification to notification and protective action recommendations due to accuracy and timeliness. The inspectors interviewed emergency preparedness staff responsible for oversight of the DEP program, reviewed DEP scenarios, and assessed the apparent cause report performed by Exelon in association with IR 02444424. The focus of the inspection was to assess the evaluation and to ensure the corrective actions were appropriate due to the circumstances.
b. Findings and Observations
No findings were identified. The inspectors reviewed Exelons apparent cause evaluation (ACE) report for IR 02444424 to evaluate the degraded ERO performance in regards to DEP failures. The inspectors also reviewed individual IRs that documented prior failures leading up to the ACE. Exelon determined the primary cause for the multiple failures was a combination of factors including ERO turnover attendance, a lack of station emphasis on the importance of the ERO, and a lack of a strong interface between the operations department and the emergency preparedness department. The inspectors reviewed the corrective actions implemented following the ACE. These actions included increased ERO training, required quarterly meetings between the operations and emergency preparedness staffs, increased management emphasis placed on supporting emergency preparedness as a station, and imposing a moratorium on taking credit for NRC DEP PIs for the second quarter of 2015 until appropriate corrective actions had been implemented.
Exelons immediate and long-term corrective actions proved to be effective as evidenced by significantly improved DEP scores since completion of the ACE. Exelon had 83 successful DEP calls out of a possible 84 following implementation of the corrective actions.
The inspectors concluded that Exelons immediate and long-term corrective actions were effective, and there were no apparent DEP performance issues identified since implementing the corrective actions. Specifically, placing a higher significance from management on the importance of the ERO as a station, creating a stronger relationship between operations and emergency preparedness, providing additional ongoing training to the ERO, and placing a stronger emphasis on accountability during ERO turnover have resulted in positive changes in the emergency preparedness department as a whole and not just in terms of DEP performance. The large number of DEP failures that the station incurred during the late part of 2014 could not have been reasonably identified and prevented by prior isolated DEP failures. Therefore, no findings of significance were identified. Additional planned corrective actions associated with the improvement of the emergency preparedness department as a whole will be reviewed during future NRC inspections.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events (2 samples)
a. Inspection Scope
For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the event to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.
- Unit 1 Uninterruptible Power Supply (UPS) 162B failure on July 29, 2016
- Event Notification 52133 for Unexpected Isolation of Both Trains of Emergency Condensers on July 29, 2016
b. Findings
No findings were identified.
.2 (Closed) Licensee Event Report 05000220/2016-001-00:
Inoperable Due to Simultaneous Opening of Airlock Doors (1 sample)
On June 1, 2016, Unit 1 operators declared secondary containment inoperable when a worker opened both inner and outer airlock doors on the reactor building 261 foot elevation simultaneously while traversing through the airlock, similar to what was reported in Licensee Event Reports (LERs) 05000220/2014-004-00, 05000220/2014-005-00, 05000220/2014-006-00, 05000220/2015-001-00, 05000220/2015-002-00, and 05000220/2015-003-00. The doors were both open for a period of about 5 seconds, so the worker entered TS 3.4.3 and promptly exited TS 3.4.3 when the inner door was verified closed. The cause of this event was determined to be the failure of the worker to use human performance tools and follow the posted expectations for passage through the airlock doors. The inspectors reviewed the reactor building differential pressure as recorded by the plant process computer for the time that both doors were open, which indicated that the actual differential pressure remained negative and was unaffected by the brief simultaneous opening of the airlock doors.
Corrective actions for this event included disciplinary action administered for the individual entering the airlock. Corrective actions from the previous LERs for this condition included site communication on the proper method for operating the airlock doors, installation of a camera monitoring system at frequently used airlock doors, establishing and implementing training to emphasize the significance of the airlock doors, and disciplinary action for the individuals involved in the previous events. This event was entered into Exelons CAP as IR 02676493.
Since this LER was issued by NMPNS, Amendment No. 223 to Renewed Facility Operating License No. DPR-63 was approved. This license amendment modified TS definition 1.2, TS Limiting Condition for Operation 3.4.3.a.1 and Surveillance Requirement 4.4.3.b.1 to allow for brief, inadvertent simultaneous openings of secondary containment inner and outer access doors during normal entry and exit without having to enter into TS 3.4.3 action statements. Therefore, an opening of the secondary containment airlock doors for transit, such as the event reported in this LER, no longer affects secondary containment operability and is no longer a reportable event, per 10 CFR 50.73.
The inspectors reviewed the LER for accuracy and the adequacy of proposed and completed corrective actions. No findings or violations of NRC requirements were identified. This LER is closed.
4OA6 Meetings, Including Exit
On October 6, 2016, the inspectors presented the inspection results to Mr. Robert Kreider, Plant Manager, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation (NCV).
10 CFR 50.54q(2) requires, in part, that the license holder shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E and, for nuclear power reactor licensees, the planning standards of § 50.47(b). 10 CFR 50.47(b)(14) requires, in part, periodic exercises be conducted to evaluate major portions of emergency response capabilities and develop and maintain key skills.
Exelon procedure EP-AA-122-100, Drills and Exercise Planning and Scheduling, Revision 6, implements this planning standard and requires health physics drills be performed every 6 months. Contrary to the above, from December 28, 2015 to July 15, 2016 Exelon failed to appropriately implement its approved emergency plan by not meeting planning standard 10 CFR 50.47(b)(14). Specifically, Exelon failed to conduct and document the performance of a required health physics drill for the second half of 2015 as required by step 4.4 of Exelon procedure EP-AA-122-100. This performance deficiency was determined to be more than minor because it impacted the Emergency Preparedness cornerstone objective of ERO readiness to ensure that Exelon is capable of implementing adequate measures to protect the health and safety of the public and its workers in the event of a radiological emergency. The finding was evaluated using IMC 0609 Appendix B, Emergency Preparedness Significance Determination Process. The finding was determined to affect planning standard 10 CFR 50.47(b)(14) and matched an example of a degraded planning standard function. Therefore, the finding was determined to be of very low safety significance (Green). Exelon has entered this issue into its CAP as IR 02686128.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- P. Orphanos, Site Vice President
- R. Kreider, Plant Manager
- A. Sterio, Director, Site Engineering
- B. Knowlton, Site Engineer
- B. Scaglione, Manager Engineering
- B. Varga, Regulatory Assurance
- D. Bradshaw, System Engineering
- D. Moore, Manager Regulatory Assurance
- D. Tulowiecki, Manager Site Radiation Protection
- J. Gerber, Manager Site Chemistry, Environment and Radwaste
- K. Kristensen, Regulatory Principle Engineer
- L. Albrech, Chief Chemistry Technician
- M. Busch, Director Site Operations
- M. Khan, Senior Manager Engineering
- M. Kunzwiler, Manager Site Security
- M. Revelle, Chemistry
- P. Kehoe, Engineering Analyst
- P. Lucarriello, Radiation Protection Technician
- S. Homoki, Senior Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Closed
- 05000220/2016-001-00 LER
Secondary Containment Inoperable Due to Simultaneous Opening of Airlock Doors