IR 05000413/2013004
| ML13301A711 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/28/2013 |
| From: | Bartley J NRC/RGN-II/DRP/RPB1 |
| To: | Henderson K Duke Energy Corp |
| References | |
| IR-13-004 | |
| Download: ML13301A711 (27) | |
Text
October 28, 2013
SUBJECT:
CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000413/2013004, 05000414/2013004
Dear Mr. Henderson:
On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station Units 1 and 2. The enclosed inspection report documents the inspection results which were discussed on October 3, 2013, with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green). The finding did not involve a violation of NRC requirements. If you disagree with this finding, 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 II, and the NRC resident inspector at the Catawba Nuclear Station.
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket Nos.: 50-413, 50-414, 72-45 License Nos.: NPF-35, NPF-52
Enclosure:
Integrated Inspection Report 05000413/2013004, 05000414/2013004 w/Attachment: Supplemental Information
REGION II==
Docket Nos.:
50-413, 50-414, 72-45
License Nos.:
Report Nos.:
05000413/2013004, 05000414/2013004
Licensee:
Duke Energy Carolinas, LLC
Facility:
Catawba Nuclear Station, Units 1 and 2
Location:
York, SC 29745
Dates:
July 1, 2013 through September 30, 2013
Inspectors:
A. Hutto, Senior Resident Inspector
R. Cureton, Resident Inspector
M. Coursey, Reactor Inspector (Section 1R08)
A. Nielsen, Senior Health Physicist (Section 2RS8
R. Hamilton, Senior Health Physicist (Section 2RS1)
R. Williams, Reactor Inspector (Section 1R08)
Approved by:
Jonathan H. Bartley, Chief
Reactor Projects Branch 1
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000413/2013-004, 05000414/2013-004; 7/1/2013 - 9/30/2013; Catawba Nuclear Station,
Units 1 and 2; Mitigating Systems
The report covered a three-month period of inspection by the resident inspectors and four Region-based inspectors. One Green finding was identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red)using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP)dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 12, 2012. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process revision 4.
Cornerstone: Mitigating Systems
- Green: A self-revealing finding was identified for inadvertent operation of the Unit 1 Standby Makeup Pump (SMP) during the performance of a job performance measure (JPM). The licensed operator performing the JPM operated plant equipment which was contrary to procedural requirement to only simulate equipment operation.
The inspectors determined that operation of plant equipment during the performance of a JPM was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems attribute of Equipment Performance and adversely affected cornerstone objective because the SMP was unavailable to perform its safety function during unplanned testing and maintenance. The finding was determined to be of very low safety significance (Green), based on the results of a detailed risk assessment and an external events. The finding was not assigned a cross cutting aspect because the PD resulted from an isolated human performance error. (Section 4OA3)
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near 100 percent Rated Thermal Power (RTP) for the entire inspection period except for a brief power reduction to 50 percent RTP to replace a 1B main feedwater pump controller card.
Unit 2 operated at or near 100 percent RTP until September 13, 2013, when the unit was shutdown for a refueling outage.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
==1R04 Equipment Alignment
a. Inspection Scope
Partial Walkdowns:==
The inspectors performed three partial system walkdowns during the activities listed below to assess the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors performed walkdowns to identify any discrepancies that could impact the function of the system and, therefore, potentially increased risk. The inspectors reviewed applicable operating procedures and walked down system components, selected breakers, valves, and support equipment to determine if they were in the correct position to support system operation. The inspectors reviewed protected equipment sheets, maintenance plans, and system drawings to determine if the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program.
Documents reviewed are listed in the Attachment.
- 1A safety injection (NI) pump while the 1B NI pump was out of service for preventive maintenance (PM)
- Unit 2 auxiliary feedwater pumps and charging pumps while the standby shutdown facility (SSF) diesel generator was tagged out for PMs
- Service Water (RN) train A while the B train was out of service for planned outage maintenance
b. Findings
No findings were identified.
==1R05 Fire Protection
a. Inspection Scope
Fire Protection Walkdowns:==
The inspectors walked down accessible portions of the four plant areas listed below to assess the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors observed the fire protection suppression and detection equipment to determine whether any conditions or deficiencies existed which could impair the operability of that equipment. The inspectors selected the areas based on a review of the licensees safe shutdown analysis probabilistic risk assessment and sensitivity studies for fire-related core damage accident sequences. Documents reviewed are listed in the Attachment.
- Auxiliary Bldg 577 Elevation
- Unit 2 Cable Spreading Room
- Unit 1 Auxiliary Feedwater Pump Room
- RN Pump House
b. Findings
No findings were identified.
==1R06 Flood Protection Measures
a. Inspection Scope
==
The inspectors entered conduit manhole CMH-17A to verify that the cables were not submerged, that the cables were not damaged or degraded, and that the sump pumps were functioning properly. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
==1R08 Inservice Inspection (ISI) Activities (Unit 2)
a. Inspection Scope
==
Non-Destructive Examination Activities and Welding Activities: The inspectors conducted an on-site review of the implementation of the licensees Inservice Inspection (ISI) Program for monitoring degradation of the reactor coolant system, emergency feedwater systems, risk-significant piping and components, and containment systems in Unit 2. The inspectors activities included a review of non-destructive examinations (NDEs) to evaluate compliance with the applicable edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),Section XI (Code of record: 1998 Edition with Addenda 2000), and to verify that indications and defects (if present) were appropriately evaluated and dispositioned in accordance with the requirements of the ASME Code Section XI acceptance standards.
The inspectors directly observed or reviewed records of the following NDE mandated by the ASME Code to evaluate compliance with the ASME Code Section XI and Section V requirements and, if any indications and defects were detected, to evaluate if they were dispositioned in accordance with the ASME Code or an NRC-approved alternative requirement.
- Ultrasonic Examination (UT) of Vessel Upper Head Penetration (VUHP) Nozzles 11, 14, 23, 24, 26, and 77 (Reviewed Records)
- Liquid Penetrant Examination (PT) for 2-R-FW-0100 (Reviewed Records)
The inspectors observed the welding activities referenced below and reviewed associated documents in order to evaluate compliance with procedures and the ASME Code. The inspectors reviewed the work order, repair and replacement plan, weld data sheets, welding procedures, procedure qualification records, welder performance qualification records, and NDE reports.
- WO 01966379, Replace 2KC72, dated 3/14/2012
- WO 01966384, Replace Valve 2KC-479, dated 3/17/2012
During non-destructive surface and volumetric examinations performed since the previous refueling outage, the licensee did not identify any relevant indications that were analytically evaluated and accepted for continued service. Therefore, no NRC review was completed for this inspection procedure attribute.
PWR Vessel Upper Head Penetration Inspection Activities: For the Unit 2 vessel head, a bare metal visual (BMV) examination and a volumetric examination were required this outage pursuant to 10 CFR 50.55a(g)(6)(ii)(D). The inspectors reviewed records of the Unit 2 BMV examination. The inspectors also observed and reviewed records of ultrasonic examinations (UT) for penetration Nos. 11, 14, 23, 24, 76, and 77, to evaluate if the activities were conducted in accordance with the requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D). In particular, the inspectors evaluated if the required BMV and UT examination scopes/coverages were achieved and limitations (if applicable) were recorded in accordance with the licensees procedures. Additionally, the inspectors evaluated if the licensees criteria for visual and UT examination quality and instructions for resolving interference and masking issues were consistent with 10 CFR 50.55a.
The licensee did not identify any relevant indications that were accepted for continued service during the BMV exam. Additionally, the licensee did not perform any welding repairs to the vessel head penetrations since the beginning of the last Unit 2 refueling outage.
Boric Acid Corrosion Control (BACC) Inspection Activities: The inspectors reviewed the licensees BACC program activities to ensure implementation with commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary, and applicable industry guidance documents. Specifically, the inspectors performed an on-site record review of procedures and the results of the licensees containment walkdown inspections performed during the current fall refueling outage. The inspectors also interviewed the BACC program owner, conducted an independent walkdown of containment to evaluate compliance with licensees BACC program requirements, and verified that degraded or non-conforming conditions, such as boric acid leaks, were properly identified and corrected in accordance with the licensees BACC and corrective action programs.
The inspectors reviewed the following evaluations and corrective actions related to evidence of boric acid leakage to evaluate if the corrective actions completed were consistent with the requirements of the ASME Code Section XI and 10 CFR Part 50, Appendix B, Criterion XVI.
- Excessive rust colored boron on valve body
- Excessive boron deposits on tufline valve
- 2-NR-VA-114 Excessive Active Boron Leak
Steam Generator (SG) Tube Inspection Activities: The inspectors reviewed the Unit 2 eddy current (EC) examination activities in SGs A, B, C and D to evaluate the inspection activities against the licensees Technical Specifications, NRC commitments, ASME Section XI, and Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines. The inspectors reviewed the scope of the EC examinations to verify it included the applicable potential areas of tube degradation. The inspectors also verified that appropriate inspection scope expansion criteria were planned based on inspection results. Additionally, the inspectors reviewed EC examination status reports to ensure that all tubes with relevant indications were appropriately screened for in-situ pressure testing. Based on the EC examination results, no new degradation mechanisms were identified, no EC scope expansion was required, and none of the SG tubes examined met the criteria for in-situ pressure testing.
The inspectors reviewed the last Condition Monitoring and Operational Assessment report to assess the licensees prediction capability for maximum tube degradation. The inspectors review also included the licensees repair criteria and repair process to ensure they were consistent with plant Technical Specifications and industry guidelines.
Three tubes in SG B and four tubes in SG C met the criteria for repair or plugging. The inspectors also reviewed the primary to secondary leakage (e.g., SG tube leakage)history for the last operating cycle. The inspectors noted that primary to secondary leakage was below the detection threshold during the previous operating cycle.
In addition, the inspectors reviewed documentation to ensure that data analysts, EC probes, and equipment configurations were qualified to detect the existing and potential SG tube degradation mechanisms. The inspectors review included a sample of site-specific Examination Technique Specification Sheets (ETSSs) to ensure that their qualification was consistent with Appendix H or I of the Electric Power Research Institute Pressurized Water Reactor Steam Generator Examination Guidelines, Revision 7. The inspectors also directly observed a sample of EC data acquisition in SG A and C (Cold Leg and Hot Leg sides). Furthermore, the inspectors reviewed a sample of EC data with a qualified data analyst including the following tubes: SG A (R35C36, R34C34 and R31C33) and SG C (R44C23, R38C96, R38C97, and R46C60). The inspectors reviewed the licensees corrective actions for indications (either from EC or secondary side visual inspections) of potential loose parts on the SG primary and secondary side, including direct observation of Foreign Object Search and Retrieval (FOSAR) activities.
Identification and Resolution of Problems: The inspectors performed a review and sample of ISI-related problems that were identified by the licensee and entered into the corrective action program as problem identification program documents (PIPs). The inspectors reviewed the PIPs to confirm the licensee had appropriately described the scope of the problem and had initiated corrective actions. The review also included the licensees consideration and assessment of operating experience events applicable to the plant. The inspectors performed this review to ensure compliance with 10CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
==1R11 Licensed Operator Requalification (LOR) Program and Licensed Operator Performance
a.
==
Inspection Scope
Quarterly LOR Activity Review: The inspectors observed Active Simulator Exam ASE-27 to assess the performance of licensed operators during a license operator requalification simulator examination. The simulator scenario involved an atmospheric steam dump failure followed by a loss of a vital bus and one train of component cooling water. The scenario progressed with a loss of feedwater with a failure of the reactor to trip and a subsequent loss of heat sink. The inspectors assessed overall crew performance, clarity and formality of communications, use of procedures, alarm response, control board manipulations, group dynamics and supervisory oversight. The inspectors observed the post-exercise critique to determine whether the licensee identified deficiencies and discrepancies that occurred during the simulator training.
Documents reviewed are listed in the Attachment.
Quarterly Licensed Operator Performance Review: The inspectors observed operators in the main control room and assessed their performance during Unit 2 shutdown and mode changes to refueling outage 2EOC19. Documents reviewed are listed in the
.
b. Findings
No findings were identified.
==1R12 Maintenance Effectiveness
a. Inspection Scope
==
The inspectors reviewed the activities listed below for items such as: 1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule; 4) characterizing reliability issues for performance; 5) trending key parameters for condition monitoring; 6) charging unavailability for performance; 7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and 8) appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1).
For each item selected, the inspectors performed a detailed review of the problem history and surrounding circumstances, evaluated the extent of condition reviews as required, and reviewed the generic implications of the equipment and/or work practice problem. Documents reviewed are listed in the Attachment.
- PIP C-13-6169, F VI compressor tripped on High Vibration
b. Findings
No findings were identified.
==1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
==
The inspectors reviewed the following six activities to determine if the appropriate risk assessments were performed prior to removing equipment for work. When emergent work was performed, the inspectors reviewed the risk assessment to determine that the plant risk was promptly reassessed and managed. The inspectors reviewed the use of the licensees risk assessment tool and risk categories in accordance with Nuclear System Directive (NSD) 415, Operational Risk Management (Modes 1-3), to verify there was appropriate guidance to comply with 10 CFR 50.65(a)(4). Documents reviewed are listed in the Attachment.
- Equipment protection plan for 1B1 component cooling water pump out of service for maintenance (yellow risk)
- PIP C-13-5738, Normal incoming breaker to 2EMXH tripped
- PIP C-13-5905, Unit 1 SSF out of service due to inadvertent pump start (Yellow risk)
- PIP C-13-6105, Steam Leak upstream of 1CF-27 (1A S/G CF control valve inlet isolation) (Yellow Risk)
b. Findings
No findings were identified.
==1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
==
The inspectors evaluated the technical adequacy of the five operability evaluations or functionality assessments listed below to determine if Technical Specification (TS)operability was properly justified and the subject components and systems remained available such that no unrecognized increase in risk occurred. The inspectors reviewed the operability determinations to verify that they were made as specified by NSD 203, Operability. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) to determine that the systems and components remained available to perform their intended function. Documents reviewed are listed in the Attachment.
- PIP C-13-5588, KC Pump 1B1 motor outboard bearing oil discolored
- PIP C-13-5889, 1B NV pump seal leakage
- PIP C-13-5962, Formal Functionality Assessment for Standby Makeup Pump #1
- PIP C-13-6160, Diesel Generator Fuel Oil solenoids wired with 1A fuses while manufactures drawings indicate the fuses draw up to 1.5A
- PIP C-13-6148, Rounds operator discovered oil level is not visible in sight glass for 2A NV pump reduction gear.
b. Findings
No findings were identified.
==1R18 Plant Modifications
a. Inspection Scope
==
The inspectors reviewed the two following plant modifications to verify the adequacy of the modification package, and to evaluate the modification for adverse affects on system availability, reliability and functional capability. Documents reviewed are listed in the
.
- EC 104418, SSF D/G Voltage Regulator Optional Replacement (Permanent)
- WO 02049314 Alternate Power to Step Up Transformer Bank #3 (Temporary)
b. Findings
No findings were identified.
==1R19 Post Maintenance Testing
a. Inspection Scope
==
The inspectors reviewed the six post-maintenance tests listed below to determine if procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensees test procedures to determine if the procedures adequately tested the safety function(s) that may have been affected by the maintenance activities, that the acceptance criteria in the procedures were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedures had been properly reviewed and approved. The inspectors also witnessed the tests and/or reviewed the test data to determine if test results adequately demonstrated restoration of the affected safety function(s). Documents reviewed are listed in the Attachment.
- Standby Makeup Pump #1 Performance test following pump inspections
- 2B Diesel Generator following pre-outage maintenance activities
- 1A Diesel Generator following diesel down day maintenance activities
- E Instrument Air Compressor surge test following compressor rebuild
- SSF Diesel Generator test following maintenance activities
- 2B Diesel Generator following outage maintenance activities
b. Findings
No findings were identified.
==1R20 Refueling and Other Outage Activities
a. Inspection Scope
==
The inspectors conducted reviews and observations for the following Unit 2 outage activities to ensure that: 1) the licensee considered risk in developing the outage plan; 2) the licensee adhered to the outage plan to control plant configuration based on risk; 3)that mitigation strategies were in place for losses of key safety functions; and 4) the licensee adhered to operating license and TS requirements. Documents reviewed are listed in the Attachment.
- Outage risk management plan/assessment
- Clearance activities
- Reactor coolant system instrumentation
- Plant cool down
- Mode changes from Mode 1 (power operation) to No Mode (defueled)
- Shutdown decay heat removal and inventory control
- Containment closure
- Refueling activities
b. Findings
No findings were identified.
==1R22 Surveillance Testing
a. Inspection Scope
==
For the five tests listed below, the inspectors witnessed testing and/or reviewed the test data to determine if the SSCs involved in these tests satisfied the requirements described in the Technical Specifications, the UFSAR, and applicable licensee procedures, and that the tests demonstrated that the SSCs were capable of performing their intended safety functions.
Surveillance Tests
- PT/2/A/4350/002 B, Diesel Generator 2B Operability Test
- PT/0/A/4200/017 B, Standby Shutdown Facility Diesel Isochronous Test
- MP/0/A/7150/005, Ice Basket Weight Determination
In-Service Tests
- PT/2/A/4200/004 B, Containment Spray Pump 2A Performance Test
- PT/2/A/4250/003 B, Auxiliary Feedwater Motor Driven Pump 2B Performance Test
b. Findings
No findings were identified.
RADIATION SAFETY
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
Hazard Assessment and Instructions to workers During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas, High Radiation Areas, and Locked High Radiation Areas (LHRA)s established within the Radiologically Controlled Area (RCA) of the auxiliary building and radioactive waste (radwaste) processing and storage locations. The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. Inspectors reviewed spent fuel dry cask storage installations and evaluated postings, boundary dosimetry deployment, and recent survey results. The inspectors reviewed survey records for several in-plant areas including surveys for alpha emitters, airborne radioactivity, gamma surveys with a range of dose rate gradients, and pre-job surveys for upcoming tasks. The inspectors also discussed changes to plant operations that could contribute to changing radiological conditions since the last inspection. For selected containment entries, the inspectors attended pre-job briefings and reviewed radiation work permit (RWP) details to assess communication of radiological control requirements and current radiological conditions to workers.
Hazard Control and Work Practices The inspectors evaluated access barrier effectiveness for selected LHRA locations and discussed procedural guidance for LHRA and Very High Radiation Area (VHRA) controls with Health Physics (HP) supervisors.
The inspectors observed and evaluated controls for the storage of irradiated material within the Spent Fuel Pool. Established radiological controls (including airborne controls) were evaluated for maintenance. In addition, the inspectors reviewed and discussed licensee controls for areas where dose rates could change significantly.
Through direct observations and interviews with licensee staff, the inspectors evaluated occupational workers adherence to selected RWPs and HP technician proficiency in providing job coverage. Electronic dosimeter alarm set points and worker stay times were evaluated against area radiation survey results for maintenance work. The inspectors reviewed the use of personnel dosimetry (extremity dosimetry and multibadging in high dose rate gradients) for the reactor head and steam generator maintenance work. The inspectors also evaluated worker response to dose and dose rate alarms during selected work activities. The inspector also observed the HP organization response to an unplanned dose rate alarm.
Control of Radioactive Material The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.
Problem Identification and Resolution The inspectors reviewed Corrective Action Program (CAP) documents associated with radiological hazard assessment and exposure control. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with licensee procedures. The inspectors also reviewed recent self-assessment results.
The inspectors evaluated radiation protection activities against the requirements and guidance of Updated Final Safety Analysis Report (UFSAR) Section 12; Technical Specifications Section 5.7; 10 CFR Parts 19 and 20; Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants; and approved licensee procedures. Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in the
.
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation
a. Inspection Scope
Waste Processing and Characterization: During inspector walk-downs, accessible sections of the liquid and solid radwaste processing systems were assessed for material condition and conformance with system design diagrams. Inspected equipment included radwaste storage tanks, resin transfer piping, resin and filter packaging components, and abandoned reactor coolant sampling equipment. The inspectors discussed component function, processing system changes, and radwaste program implementation with licensee staff.
The 2011 Radioactive Effluent Report and radionuclide characterizations from 2006 - 2013 for each major waste stream were reviewed and discussed with radwaste staff.
For primary resin and Dry Active Waste (DAW) the inspectors evaluated analyses for hard-to-detect nuclides, reviewed the use of scaling factors, and examined quality assurance comparison results between licensee waste stream characterizations and outside laboratory data. Waste stream mixing and concentration averaging methodology for resin and filter waste streams were evaluated and discussed with radwaste staff.
The inspectors also reviewed the licensees procedural guidance for monitoring changes in waste stream isotopic mixtures.
Radioactive Material Storage: During walk-downs of indoor and outdoor radioactive material storage areas, the inspectors observed the physical condition and labeling of storage containers and the posting of Radioactive Material Areas. The inspectors also reviewed licensee procedural guidance for storage and monitoring of radioactive material.
Transportation: Selected shipping records were reviewed for consistency with licensee procedures and compliance with NRC and Department of Transportation (DOT)regulations. The inspectors reviewed emergency response information, DOT shipping package classification, waste classification, radiation survey results, and evaluated whether receiving licensees were authorized to accept the packages. Licensee procedures for opening and closing Type A shipping casks were compared to manufacturer requirements. In addition, training records for selected individuals currently qualified to ship radioactive material were reviewed. The inspectors were unable observe shipment preparation activities due to a lack of outgoing shipments during the week of inspection.
Problem Identification and Resolution: The inspectors reviewed CAP documents in the areas of shipping and radwaste processing. The inspectors evaluated the licensees ability to identify and resolve the identified issues. The inspectors also reviewed recent self-assessment results.
Radwaste processing, radioactive material handling, and transportation activities were reviewed against the requirements contained in the licensees Process Control Program, UFSAR Chapter 11, 10 CFR Part 20, 10 CFR Part 61, 10 CFR Part 71, and 49 CFR Parts 172-178. Licensee activities were also evaluated against guidance provided in the Branch Technical Position on Waste Classification (1983) and NUREG-1608.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee data to confirm the accuracy of reported PI data for the four indicators during periods listed below. To determine the accuracy of the reported PI elements, the reviewed data was assessed against PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, Rev. 6. Documents reviewed are listed in the Attachment.
Cornerstone: Initiating Events
- Unplanned Power Changes, Units 1 & 2
Cornerstone: Mitigating Systems
- Mitigating Systems Performance Index - Residual Heat Removal, Units 1 & 2
The inspectors reviewed the licensees procedures and methods for compiling and reporting the PIs including the Reactor Oversight Program Mitigating Systems Performance Indicator Basis Document for Catawba. The inspectors reviewed the raw data for the PIs listed above for the period of July 1, 2012, through June 30, 2013. The inspectors also independently screened TS Action Item Logs, selected control room logs, work orders and surveillance procedures, and maintenance rule failure determinations to determine if unavailability/unreliability hours were properly reported.
The inspectors compared the licensees raw data against the graphical representations and specific values contained on the NRCs public web page for 2012-2013. The inspectors also reviewed the past history of PIPs for systems affecting the Mitigating Systems Performance Indicators listed above for any that might have affected the reported values.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Daily Review
As required by Inspection Procedure 71152, Problem Identification and Resolution, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensees corrective action program. This was accomplished by reviewing copies of PIPs, attending selected daily Site Direction and PIP screening meetings, and accessing the licensees computerized database.
.2 Annual Follow-up of Selected Issues
a. Inspection Scope
Operator Workarounds: The inspectors reviewed the cumulative effects of deficiencies that constituted operator workarounds to determine if they could affect: the reliability, availability, and potential for misoperation of a mitigating system; multiple mitigating systems; or the ability of operators to respond in a correct and timely manner to plant transients and accidents. The inspectors also assessed if operator workarounds were being identified and entered into the licensees corrective action program at an appropriate threshold.
b. Findings
No findings were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion (NOED)
.1 (Closed) Licensee Event Report (LER) 05000413/2013-01-00, Special Report -
Radioactive Source Discovered Missing During Source Inventory
On May 15, 2013, the licensee notified the NRC that a radioactive source from an abandoned radiation monitor containing approximately 0.03 microcuries of Uranium-234 could not be found during a routine inventory. As appropriate, the inspectors:
1) reviewed the LER; 2) reviewed the causal evaluation and corrective actions; and 3) discussed the event with knowledgeable licensee staff. The inspectors noted that the source was likely lost during removal of a pre-amplifier from the abandoned radiation monitor and subsequently disposed of as radwaste. 10 CFR 20.1801 required licensees to secure licensed materials stored in controlled or unrestricted areas from unauthorized removal or access. The inspectors concluded that the improper handling and disposal of the source was a violation of 10 CFR 20.1801. However, the inspectors determined that the loss was of no safety significance due to the low activity of the source and the likelihood of its disposal as radwaste. The failure to comply with 10 CFR 20.1801 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
.2 Inadvertent Standby Makeup Pump Start
a. Inspection Scope
On July 17, 2013, the Unit 1 SMP was inadvertently started during the performance of license requalification training while the pump was isolated. The inspectors reviewed the licensees actions to recover from the event and assessed the adequacy of subsequent maintenance activities to restore the pump to operable status. Documents reviewed are listed in the Attachment.
b. Findings
Introduction:
A Green self-revealing finding was identified for inadvertent operation of the Unit 1 SMP during the performance of a job performance measure (JPM). The licensed operator performing the JPM operated plant equipment which was contrary to procedural requirement to only simulate equipment operation.
Description:
An SRO was performing a JPM in the SSF when he inadvertently started the Unit 1 SMP with the pump suction and discharge valves closed causing the discharge relief valve to lift. Operations Training Management Procedure 4.1, JPM Exam Preparation and Administration, Attachment 1, stated that plant equipment shall not be operated. The pump was secured and tagged out to perform several inspections to ensure the pump was not damaged and to replace the discharge relief valve as it did not fully reseat. The pump was unavailable for approximately 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />.
Analysis:
The inspectors determined that operation of plant equipment during the performance of a JPM was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems attribute of Equipment Performance and adversely affected cornerstone objective because the SMP was unavailable to perform its safety function during unplanned testing and maintenance.
The finding was screened using Inspection Manual Chapter (IMC) 0609 Appendix F, Fire Protection Significance Determination Process (SDP), issued February 28, 2005, because the SMP was credited for post-fire safe shutdown for certain fire areas. The finding was determined to require a phase 2 analysis based on a high degradation rating and a duration factor of less than three days. The SMP was also credited to mitigate certain external events and station blackout. Therefore, the inspectors determined that a detailed risk evaluation was required per IMC 0609 Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued June 19, 2012, as the finding represented an actual loss of function of one or more non-tech spec trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The finding was determined to be of very low safety significance (Green), based on the results of a detailed risk assessment and an external events review by a senior risk analyst. The inputs for the risk analysis were that the Unit 1 SMP train condition failure to continue running was set to true for the 42 hour4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> duration that the pump was tagged out. The finding was not assigned a cross cutting aspect because the PD resulted from an isolated human performance error.
Enforcement:
This finding does not involve enforcement action because no violation of a regulatory requirement was identified. This finding has been entered into the licensees corrective action program as PIP C-13-5905. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000413/2013004-01, Inadvertent Operation of the Unit 1 Standby Makeup Pump.
4OA5 Other Activities
Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 3, 2013, the resident inspectors presented the inspection results to Mr.
Kelvin Henderson and other members of licensee management. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- T. Arlow, Emergency Planning Manager
- J. Boughman, ISI Coordinator
- D. Cantrell, Chemistry Manager
- C. Cauthen, SG ISI Coordinator
- R. Doss, Evaluation Standards
- T. Hamilton, Engineering Manager
- R. Hart, Regulatory Compliance Manager
- K. Henderson, Site Vice-President
- T. Jenkins, Superintendent of Maintenance
- C. Kamilaris, Organizational Effectiveness Manager
- B. Mitchell, Site BACCP Owner
- A. Orton, Nuclear Training Manager
- T. Pasour, Regulatory Affairs
- K. Phillips, Work Control Manager
- S. Putnam, Superintendent of Operations
- P. Simbrat, Regulatory Compliance Engineer
- T. Simril, Plant Manager
- J. Smith, Radiation Protection Manager
- W. Suslick, Design Support Services
- S. West, Security Manager
LIST OF REPORT ITEMS
Closed
- 05000413/2013-01-00 LER Special Report - Radioactive Source Discovered Missing During Source Inventory (Section 4OA3)
- 050000413/2013004-01 FIN Inadvertent Operation of the Unit 1 Standby Makeup Pump (Section 4AO3)