IR 05000458/2013005
| ML14044A033 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/13/2014 |
| From: | Allen D NRC/RGN-IV/DRP/RPB-C |
| To: | Olson E Entergy Operations |
| References | |
| IR-13-005 | |
| Download: ML14044A033 (65) | |
Text
February 13, 2014
SUBJECT:
RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2013005 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Olson:
On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station, Unit 1. On January 16, 2014, the NRC inspectors discussed the results of this inspection with Mr. R. Gadbois, General Manager, Plant Operations 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) in this report.
This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.
A violation of technical specification 3.6.1.10 was identified. Because the violation was identified during the discretion period described in Enforcement Guidance Memorandum 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation, subject to a timely license amendment request being submitted.
If you contest the violations or significance of these non-cited violations, 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 IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the River Bend Station.
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511 If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the River Bend Station.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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/
Donald B. Allen, Branch Chief Project Branch C Division of Reactor Projects
Docket No.: 50-458 License No.: NPF-47
Enclosure:
Inspection Report 05000458/2013005 w/Attachments:
1) Supplemental Information 2) Request for Information for the TI 2515-182 Phase 2 Inspection 3) Request for Information for the Occupational/Public Radiation Safety Inspection
Electronic Distribution to River Bend Station
SUMMARY
IR 05000458/2013005; 09/29/2013 - 12/31/2013; River Bend Station; Integrated Resident and
Regional Report; Radioactive Gaseous and Liquid Effluent Treatment; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, & Transportation
The inspection activities described in this report were performed between September 29, 2013, and December 31, 2013, by the resident inspectors at the River Bend Station, nine inspectors from the NRCs Region IV office, and an inspector from the NRCs Office of Nuclear Security and Incident Response. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding in this report. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,
Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Public Radiation Safety
- Green.
Inspectors reviewed a self-revealing non-cited violation of 10 CFR 20.1501(a)because the licensee failed to perform radiation surveys to evaluate radiological conditions associated with a 5 gallons per minute water leak to ensure compliance with 10 CFR 20.1406(c). The leak continued for approximately five months before a radiological survey was completed that identified the leak source to be the circulating water blowdown system which contained liquid radioactive waste. This issue was entered into the corrective action program as Condition Report CR-RBS-2013-02400.
The failure to perform a timely radiological survey was a performance deficiency. The finding was more than minor because if left uncorrected it could have led to a more significant concern. If not for the outage, the unidentified releases would have continued depositing radioactivity onsite and into the environment. Using NRC Manual Chapter 0609,
Appendix DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Public Radiation Safety Significance Determination Process, issued February 12, 2008, the finding was determined to be of very low safety significance because it was not a failure to implement an effluent program and public dose was not greater than Appendix I criteria or 10 CFR 20.1301(e). The finding had a cross-cutting aspect associated with the problem identification and resolution component because the licensee did not thoroughly evaluate the source of the leak in a timely manner P.1(c) (Section 2RS6).
- SL-IV. The inspectors identified two examples of a Severity Level IV non-cited violation of 10 CFR 50.71(e) for failure to update the Updated Safety Analysis Report. Specifically, the licensee failed to adequately describe the Low-Level Radwaste Storage Facility and the Independent Spent Fuel Storage Installation in the Updated Safety Analysis Report in accordance with Regulatory Guide 1.70, Revision 3. The licensee entered the issue into their corrective action program as Condition Report CR-RBS-2013-07265.
The failure to update the Updated Safety Analysis Report to reflect changes made to the facility was a violation of regulatory requirements of 10 CFR 50.71(e), Maintenance of Records, Making of Reports. This issue was evaluated using traditional enforcement because it had the potential to impact the NRCs ability to perform its regulatory function.
The issue was characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy, issued January 28, 2013, because the erroneous information in the Updated Safety Analysis Report was not used to make an unacceptable change to the facility or procedures. Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect (Section 2RS8).
PLANT STATUS
The River Bend Station began the inspection period at 100 percent reactor power. It departed from full power as follows:
- On October 27, operators reduced power to 71 percent to perform a rod sequence exchange, turbine valve testing, a partially withdrawn rod operability test, and to remove reactor feedwater pump 1B from service to correct a steam leak from the inboard pump seal and to correct lube oil leaks on the pumps gear increaser. The licensee returned the plant to full power on October 31.
- On December 2, operators reduced power to 85 percent to remove reactor feedwater pump 1B from service to repair a steam leak from the pumps inboard shell casing. The licensee returned the plant to full power on December 2.
The plant remained at 100 percent reactor power for the remainder of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
On October 4, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for hurricane season and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the landfall of Hurricane Karen, the licensee had corrected weather-related equipment deficiencies identified during the stations walkdown of plant property.
The inspectors selected four risk-significant systems that were required to be protected from high precipitation and high winds:
- Safety-related switchgear
- Transformer yard
- Standby service water cooling tower
- Fire water system
The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by adverse weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of each individual systems protection features.
These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- October 10, low pressure core spray
- October 22, Division 1 batteries and charger, backup charger
- October 24, Division 1 control building chilled water system
- October 29, Makeup water system following system (pump and valve)maintenance
The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems or divisions were correctly aligned for the existing plant configuration.
These activities constituted four partial system walkdown samples, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
.2 Complete Walkdown
a. Inspection Scope
On October 24, the inspectors performed a complete system walkdown inspection of the reactor core isolation cooling system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
These activities constituted one complete system walkdown sample, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
- September 29, control building, 136-foot elevation
- September 30, reactor building, 141-foot, 162-foot, and 186-foot elevations
- October 1, control building, 116-foot and 95-foot elevations
- October 16, diesel generator building, 98-foot elevation
For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On October 31, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose two plant areas containing risk-significant structures, systems, and components that were susceptible to flooding:
- Diesel generator building, 98-foot elevation
- Residual heat removal C and reactor core isolation cooling rooms (Operating Experience Smart Sample 2007-02, Flooding Vulnerability Due to Inadequate Design and/Conduit/Hydrostatic Seal Barrier Concerns)
The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.
In addition, on November 21, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected two underground electrical manholes that contained risk-significant cables whose failure could disable risk-significant equipment:
- Electrical manhole EMH-600
- Electrical manhole EMH-602
The inspectors observed the material condition of the cables and splices contained in the electrical manholes and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.
These activities constitute completion of two flood protection measures samples and one bunker/manhole sample, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On November 6, the inspectors observed a portion of two annual requalification tests for licensed operators for an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.
These activities constitute completion of two quarterly licensed operator requalification program samples, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
On September 29, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to potential contamination of the normal service water system from tritium in the reactor plant component cooling water system.
In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.3 Annual Review of Requalification Examination Results (Unit 1)
The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, the River Bend Station was in the first part of the training cycle.
a. Inspection Scope
The inspector reviewed the results of the operating tests for the station to satisfy the annual inspection requirements.
On December 10, 2013, the licensee informed the lead inspector of the results:
- 6 of 6 crews passed the simulator portion of the operating test
- 43 of 43 licensed operators passed the simulator portion of the operating test
- 43 of 43 licensed operators passed the job performance measure portion of the examination
Because there were no overall failures in any of these areas, there were no required remediations performed.
The inspector completed one inspection sample of the annual licensed operator requalification program, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components:
- November 22, 2013, primary containment isolation valves
- December 5, 2013, main steam system
The inspectors reviewed the extent of condition of possible common cause structures, systems, and components failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed four risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- October 14, Fancy Point breaker maintenance
- October 22, Fancy Point switchyard battery capacitance test and switchyard backup diesel maintenance
- October 31, Fancy Point switchyard, switchgear cross connect out of service
- December 10, feedwater flow controller time delay relay replacement
The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the results of the assessments.
Additionally, on November 5, the inspectors observed portions of the reactor core isolation cooling turbine insulation repair emergent work activities that had the potential to affect the functional capability of mitigating systems.
The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components.
These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed three operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, and components:
- October 1, operability determination of salt particulate in the Division 1 diesel fuel oil (CR-RBS-2013-05803)
- October 7, functionality assessment of thermal megawatt cycling from 3089 to 3091 without operator action (CR-RBS-2013-06056)
- October 28, operability determination for trip of the Division 3 diesel output breaker during unloading of the diesel (CR-RBS-2013-06789)
The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded structures, systems, and components to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded structures, systems, and components.
These activities constitute completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed six post-maintenance testing activities that affected risk-significant structures, systems, and components:
- November 7, WO-00359884, C85-FLT1B Replace Filter with New Filter
- November 13, WO-52517719, Calibrate HVK-FTX5C per Loop Calibration Report
- November 21, WO-00366214, Perform Troubleshooting of Diesel Trip
- November 21, WO-00315887, Division 2 Emergency Diesel Generator Control Air Pressure High, Out of Specification
- November 22, WO-00361681, Emergency Diesel Generator Governor Setpoint Modification
- November 29, WO-00368107, ENS-SWG1B-ACB27-1A Would Not Open From Panel H13-P877
The inspectors reviewed licensing-and design-basis documents for the structures, systems, and components and the maintenance and post-maintenance test procedures.
The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, and components.
These activities constitute completion of six post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed eight risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:
In-service test:
- December 23, STP-309-6301, Revision 17, Division 1 EDG Fuel Oil Transfer Pump and Valve Operability Test
Containment isolation valve surveillance test:
- November 15, WO-00364294, Revision 0, EHS-MCC2F 6C/E12-MOVF004B Unitized Starter Current Injection
Reactor coolant system leak detection test:
- November 5, STP-000-0001, Revision 72, Daily Operating Logs Other surveillance tests:
- October 12, STP-052-0102, Revision 008, Partially Withdrawn Control Rod Insertion Operability Check
- October 24, STP-410-3601, Revision 7, Performance Monitoring Program for Control Building Chiller HVK-CHL1A (Division 1)
- November 4, STP-402-3601, Revision 7, Performance Monitoring Program for the Control Room Air Handling Unit HVC*ACU1A (Division 1)
- November 4, STP-509-0101, Revision 12, Main Turbine Bypass System Valve Cycle Test
- December 30, COP-0001, Revision 23, Sampling via Various Balance of Plant Systems
The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and components following testing.
These activities constitute completion of eight surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)
a. Inspection Scope
The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML12354A521 and ML13014A041 as listed in the Attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.
These activities constitute completion of three samples as defined in Inspection Procedure 71114.04-05.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
The inspectors verified the accuracy and operability of the radiation monitoring equipment used by the licensee
- (1) to monitor areas, materials, and workers to ensure a radiologically safe work environment, and
- (2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
- Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Updated Safety Analysis Report and the offsite dose calculation manual
- Selected instrumentation, including effluent monitoring instruments, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks
- Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors
- Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection
These activities constitute completion of one sample of radiation monitoring instrumentation as defined in Inspection Procedure 71124.05-05.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
The inspectors verified that the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items:
- Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection
- Effluent program implementing procedures, including sampling, monitor setpoint determinations, and dose calculations
- Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews
- Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)
- Controls used to ensure representative sampling and appropriate compensatory sampling
- Results of the inter-laboratory comparison program
- Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection
- Significant changes in reported dose values
- A selection of radioactive liquid and gaseous waste discharge permits
- Offsite dose calculation manual changes
- Latest land use census
- Records of abnormal gaseous or liquid tank discharges
- Groundwater monitoring results
- Changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater
- Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term
- Offsite notifications, and reports of events associated with spills, leaks, and groundwater monitoring results
- Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection
These activities constitute completion of one sample of radioactive gaseous and liquid effluent treatment as defined in Inspection Procedure 71124.06.
b. Findings
Introduction.
Inspectors reviewed a Green self-revealing non-cited violation of 10 CFR 20.1501(a) because the licensee failed to perform radiation surveys to evaluate radiological conditions associated with a 5 gallons per minute water leak to ensure compliance with 10 CFR 20.1406(c). The leak continued for approximately five months before a radiological survey was completed to identify the waters source.
Description.
On October 2, 2012, plant personnel found water seeping from the ground and accumulating in a ditch near the sites sewage treatment pond at a leak rate of approximately 5 gallons per minute. The leak was assumed to be waste water from the sewage treatment plant. Based on a pH and chlorine sample, the licensee further assumed that the leak was clean domestic water being delivered to the waste water treatment plant. A radiological analysis was not completed at this time. A work order was created to find and isolate the leak, but it was a low priority work item based on the assumed source of the water. Refueling Outage 17 began in February 2013. As part of the outage, the circulating water blowdown (CWBD) line was removed from service.
Around this time, plant personnel noticed that the water leak had stopped. An investigation revealed that no maintenance was performed to stop the leak. Further investigation determined that check valve 1PBS-V3014 was stuck open. This allowed CWBD system water to flow backward into the 4-inch effluent line which flowed towards the waste water treatment plant. This backflow water was also leaking through an air relief valve into a plant ditch. The liquid radwaste (LRW) system routinely discharges flow into the CWBD line upstream of the waste water treatment plant tie-in. As a result, during periods of LRW batch releases, radioactive effluents were being released into the environment via this unmonitored release path. A radiological analysis was performed on March 17, 2013, which confirmed that Co-60 had been improperly released onsite and into the environment. No accumulated water was available to determine how much tritium had also been released. There were 18 LRW batch releases discharged during this time period; approximately 25,650 gallons of diluted radioactive (waste) water leaked through the air relief valve. In the fourth quarter of 2012, in the Annual Radiological Effluent Release Report, the licensee reported that LRW discharges from its normal release pathway were 7.44 curies tritium with an average diluted concentration of 5.47E-6 microcuries/milliliter [5470 picoCuries/liter]. The licensee documented the leak in Condition Report CR-RBS-2012-06329 and the identification of the source of the leak in CR-RBS-2013-02480. The licensee also isolated the CWBD line when it was identified as the potential source of the leak.
Analysis.
The failure to perform a timely radiological survey was a performance deficiency. The finding was more than minor because if left uncorrected it could have led to a more significant concern. If not for the outage, the unidentified releases would have continued depositing radioactivity onsite and into the environment. Using NRC Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, issued February 12, 2008, the finding was determined to be of very low safety significance because it was not a failure to implement an effluent program and public dose was not greater than Appendix I criteria or 10 CFR 20.1301(e). The finding had a cross-cutting aspect associated with the problem identification and resolution component because the licensee did not thoroughly evaluate the source of the leak in a timely manner P.1(c).
Enforcement.
Title 10 CFR 20.1501(a) states that Each licensee shall make or cause to be made, surveys of areas, including the subsurface, that may be necessary for the licensee to comply with the regulations in this part. Title 10 CFR 20.1406(c) states, in part, that Licensees shall, to the extent practical, conduct operations to minimize the introduction of residual radioactivity into the site, including the subsurface, in accordance with the existing radiation protection requirements. Contrary to the above, from October 2012 to March 2013, the licensee failed to perform radiation surveys or analyses and evaluate radiological conditions of a 5 gallons per minute leak to ensure compliance with 10 CFR 20.1406(c). Since this violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-RBS-2013-02480, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000458/2013005-01, Failure to Perform a Survey on Water Leak.
2RS7 Radiological Environmental Monitoring Program
a. Inspection Scope
The inspectors verified that the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program.
The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensees technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items:
- Annual environmental monitoring reports and offsite dose calculation manual
- Selected air sampling and dosimeter monitoring stations
- Collection and preparation of environmental samples
- Operability, calibration, and maintenance of meteorological instruments
- Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement
- Selected structures, systems, and components that may contain licensed material and has a credible mechanism for licensed material to reach ground water
- Records required by 10 CFR 50.75(g)
- Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection
- Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation
- Inter-laboratory comparison program results
- Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection
These activities constitute completion of one sample of radiological environmental monitoring program as defined in Inspection Procedure 71124.07.
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
a. Inspection Scope
The inspectors verified the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:
- The solid radioactive waste system description, process control program, and the scope of the licensees audit program
- Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition
- Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
- Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest
- Audits, self-assessments, reports, and corrective action reports related to radioactive solid waste processing and radioactive material handling, storage, and transportation since the last inspection
These activities constitute completion of one sample of radioactive solid waste processing and radioactive material handling, storage, and transportation as defined in Inspection Procedure 71124.08.
b. Findings
Introduction.
The inspectors identified two examples of a Severity Level IV non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, for failure to update the Updated Safety Analysis Report. Specifically, the licensee failed to adequately describe two radioactive waste storage facilities (the Low-Level Radwaste Storage Facility (LLRWSF) and the dry spent fuel storage system or independent spent fuel storage installation (ISFSI)) in its Updated Safety Analysis Report in accordance with Regulatory Guide 1.70 (RG 1.70).
Description.
While inspecting the licensees solid radwaste management activities and storage facilities, the inspectors identified that the LLRWSF and ISFSI were not adequately described in Chapters 11 and 12 of the Updated Safety Analysis Report.
The licensee built these facilities in the owner controlled area for interim storage of low-level radioactive waste (Class A, B, or C) and long-term storage of high-level radioactive waste (i.e., spent fuel and greater than Class-C), respectively. The licensee is committed to RG 1.70, Revision 3, Standard, Format, and Content of Safety Analysis Reports for Nuclear Power Plants, which describes the information and detail to be included in each section of the Updated Safety Analysis Report. Regulatory Guide 1.70, Chapter 11, Section 4, Solid Waste Management System, specifies the design objectives and design criteria for the solid radioactive waste handling and treatment system in terms of the types of wastes, the maximum and expected volumes to be handled, and the isotopic and curie content. This section (11.4), also stipulates for dry solid waste to tabulate the maximum and expected waste inputs in terms of type, sources of waste, volume, and isotopic and curie content. Section 11.4 also discusses the methods of handling and packaging large waste materials and equipment that have been activated during reactor operation. Regulatory Guide 1.70, Chapter 12, Section 2.1, Contained Sources, provides the basis for the radiation protection design that should be described in the manner needed as input to the shield design calculations. Those sources that are contained in equipment like the radioactive waste management systems should be described. The source location in the plant should be specified so that all important sources of radioactivity can be located on plant layout drawings. Also, the safety analysis report should provide a listing of isotope, quantity, form, and use of all sources that exceed 100 millicuries (mCi). The following two examples illustrate how the licensee failed to update the Updated Safety Analysis Report, Chapter 11, Radioactive Waste Management, and Chapter 12, Radiation Protection, with the most recent information in accordance with RG 1.70.
1. In 1997, the licensee built the LLRWSF outside the protected area for interim storage
of dry, solid, low-level radioactive waste. The licensee estimated that 538 mCi are currently stored in the LLRWSF, and the facility was designed to store approximately 33 curies. During this inspection, NRC inspectors toured the facility and identified that the LLRWSF was not adequately described in Chapters 11 and 12 of the Updated Safety Analysis Report. Specifically, the description of the LLRWSF does not include the maximum isotopic and curie contents of the waste in Chapter 11.
There was also no description of isotopes, quantity, form, or use in Chapter 12 for the LLRWSF which currently exceeds 100 mCi of activity.
2. In 2000, the licensee received a Certificate of Compliance for spent fuel storage
casks. In 2005, the first spent fuel storage casks were loaded and delivered to the ISFSI. Currently, the licensee has 1,292 spent fuel bundles stored in casks on the ISFSI. During this inspection, NRC inspectors identified that the ISFSI was not adequately described in Chapters 11 and 12 of the Updated Safety Analysis Report.
Specifically, there was no description of the facility, types of waste, the maximum and expected volumes to be handled, the isotopic and curie content, or the method of handling and packaging large waste materials and equipment that had been activated during reactor operation in Chapter 11. There was no description of isotopes, quantity, form, or use of all sources exceeding 100 mCi in Chapter 12.
Analysis.
The failure to update the Updated Safety Analysis Report to reflect changes made to the facility was a violation of 10 CFR 50.71(e). This issue was evaluated using traditional enforcement because it had the potential to impact the NRCs ability to perform its regulatory function. The issue was characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the Enforcement Policy, issued January 28, 2013, because the erroneous information in the Updated Safety Analysis Report was not used to make an unacceptable change to the facility or procedures.
Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect assigned.
Enforcement.
Title 10 CFR 50.71, Maintenance of Records, requires, in part, that licensees periodically update their Updated Safety Analysis Report with submittals that include the effects of all changes made in the facility or procedures as described in the Updated Safety Analysis Report. Contrary to the above, from 1997 through the present, the licensee failed to include in a periodic update of the Updated Safety Analysis Report, changes made to the facility. Specifically, since its construction in 1997, the licensee stored an unknown amount of radioactivity in the LLRWSF, but failed to adequately describe the facility source, volume, and curie content in Chapters 11 and 12 of the Updated Safety Analysis Report. Additionally, in 2005, the licensee started using the ISFSI inside the protected area that was not described in Chapters 11 or 12 of the Updated Safety Analysis Report. In both examples, the licensee made changes to the facility as described in the Updated Safety Analysis Report, performed safety analyses and evaluations in support of these changes; however, failed to update the Updated Safety Analysis Report with the specific, detailed information required by these changes.
This violation has been entered into the licensees corrective action program as Condition Report CR-RBS-2013-07265. This Severity Level IV violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy:
NCV 05000458/2013005-02, Failure to Periodically Update the Updated Safety Analysis Report.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Reactor Coolant System Specific Activity (BI01)
a. Inspection Scope
The inspectors reviewed the licensees reactor coolant system chemistry sample analyses for the period of October 2012 through September 2013 to verify the accuracy and completeness of the reported data. The inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample on December 30. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Reactor Coolant System Total Leakage (BI02)
a. Inspection Scope
The inspectors reviewed the licensees records of reactor coolant system total leakage for the period of October 2012 through September 2013 to verify the accuracy and completeness of the reported data. The inspectors observed the performance of the reactor coolant system leakage surveillance procedure on November 5. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system leakage performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
c. Findings
No findings were identified.
.2 Semiannual Trend Review
a. Inspection Scope
The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends. The inspectors focused the trend review on maintenance effectiveness and equipment operability.
These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
.3 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected two issues for an in-depth follow-up:
- On November 5, Fitness-for-Duty Quality Assurance Review Findings
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.
- On November 14, Cumulative Operator Workarounds
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory actions for issues associated with operator workarounds. The inspectors then assessed the impact of the cumulative effect of the workarounds. The inspectors verified that the licensee appropriately prioritized the planned corrective actions, that these actions were adequate to correct the conditions, and that the overall impact of all of the conditions did not adversely impact the plant.
These activities constitute completion of two annual follow-up samples, which included one operator work-around sample, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
(Closed) Licensee Event Report 05000458/2013-001-00: Operations Prohibited by Technical Specifications for Operations with a Potential to Drain the Reactor Vessel (EA 14-031)
On March 2, 2013, with the plant in a refueling outage, the licensee performed maintenance to replace the pump seals and the flow control valve packing in the A loop of the reactor recirculation system. The maintenance constituted an operation with a potential to drain the reactor vessel (OPDRV). Technical Specification 3.6.1.10 requires an operable primary containment during an OPDRV. The licensee did not take the actions to establish an operable primary containment during the maintenance window for the reactor recirculation system. Instead the licensee met the alternative requirements as described in NRC Enforcement Guidance Memorandum (EGM) 11-003, Dispositioning Boiling Water Reactor License Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel, Revision 1. The alternative requirements that the licensee complied with include the following:
1) The inspectors verified that the licensee declared, in the control room logs, that the plant was in an OPDRV activity. In addition, the licensee took actions to ensure water inventory was maintained and that a defense-in-depth criteria, was in place prior to entering the OPDRV activity.
2) During the OPDRV activities, the reactor vessel water level was maintained at or above 23 feet over the top of the reactor pressure vessel flange.
3) The OPDRV was not conducted in Mode 4 and the licensee did not move recently irradiated fuel during the OPDRV.
4) The licensee evaluated that during the OPDRV activity, the time to drain down the water inventory from 23 feet over the top of the reactor pressure vessel flange, to the reactor pressure vessel flange was greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This was based on the calculated maximum leak rate of OPDRV activities.
5) The capability to isolate the potential leakage path during OPDRV activities before the inventory reached the reactor pressure vessel flange was maintained.
6) During OPDRV activities, more than one safety-related pump was available that was aligned to a makeup water source with the capability to inject water at greater than the maximum potential leakage rate from the reactor pressure vessel, for a minimum time period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
7) The inspectors verified that the licensee maintained two independent means of monitoring the reactor pressure vessel water level in an effort to identify the onset of a loss of inventory event during the OPDRV activity. These monitoring methods were in accordance with the requirements stipulated in EGM 11-003
Technical Specification 3.6.1.10 is applicable during movement of recently irradiated fuel assemblies in the primary containment and/or during an OPDRV. This technical specification requires that primary containment shall be maintained operable during the applicable conditions. If containment operability is not maintained, then immediate actions should be taken to suspend either of the applicable conditions (fuel movement/OPDRVs).
Contrary to the above, between 2:48 p.m. CST on March 2, 2013, and 8:30 a.m. CST on March 7, 2013, the licensee did not maintain primary containment in an operable status while conducting an OPDRV. This is a violation of NRC requirements. Because the violation was identified during the discretion period described in EGM 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation. The inspectors reviewed this licensee event report and the actions taken by the licensee. No problems were noted. This licensee event report is closed.
4OA5 Other Activities
(Closed)Temporary Instruction 2515/182 - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks
a. Inspection Scope
Leakage from buried and underground pipes has resulted in groundwater contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, NEI 09-14, Guideline for the Management of Buried Piping Integrity, (ADAMS Accession No. ML1030901420) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122) with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued Temporary Instruction 2515/182, Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, to gather information related to the industrys implementation of this initiative.
b.
Observations
The licensees buried and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of the Temporary Instruction and it was confirmed that activities which correspond to completion dates specified in the program, which have passed since the Phase 1 inspection was conducted, have been completed.
Additionally, the licensees buried and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the Temporary Instruction and responses to specific questions were submitted to the NRC headquarters staff. Based upon the scope of the review described above, Phase 2 of TI-2515/182 was completed.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On November 22, 2013, the inspectors presented the radiation safety inspection results to Mr. E. Olson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On December 19, 2013, the lead inspector obtained the final annual examination results and exited with Mr. D. Bergstrom, Senior Training Instructor. The inspector did not review any proprietary information during this inspection.
On January 16, 2014, the inspectors presented the integrated inspection results to Mr. R. Gadbois, General Manager, Plant Operations, and other members of the licensee staff.
The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Bergstrom, Senior Training Instructor
- J. Blair, Engineer, Reactor Engineering
- D. Burnett, Manager, Emergency Preparedness
- G. Bush, Manager, Material, Procurement, and Contracts
- M. Chase, Manager, Training
- J. Clark, Manager, Licensing
- C. Coleman, Manager, Engineering Programs & Components
- F. Corley, Manager, Design Engineering
- R. Creel, Superintendent, Plant Security
- T. Evans, Director, Nuclear Safety Assurance
- M. Feltner, Manager, Production
- M. Ferrentelli, Manager, Maintenance
- A. Fredieu, Manager, Outage
- R. Gadbois, General Manager, Plant Operations
- T. Gates, Assistant Operations Manager - Shift
- K. Hallaran, Manager, Chemistry
- K. Huffstatler, Senior Licensing Specialist
- V. Huffstatler, Senior HP/Chemistry Specialist, Chemistry
- G. Krause, Assistant Operations Manager - Training
- P. Lucky, Manager, Corrective Actions and Assessments
- J. Maher, Manager, System Engineering
- W. Mashburn, Director, Engineering
- M. Mella, Engineer, Reactor Engineering
- E. Neal, Acting Manager, Radiation Protection
- E. Olson, Site Vice President
- W. Renz, Director, Emergency Planning
- J. Reynolds, Assistant Operations Manager - Support
- T. Santy, Manager, Security
- T. Shenk, Manager, Operations
- J. Soileau, HP/Chemistry Specialist, Radiation Protection
- W. Spell, Environmental Specialist
- J. Vukovics, Supervisor, Reactor Engineering
- J. Wieging, Manager, Planning and Scheduling, Outages
- L. Woods, Manager, Quality Assurance
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000458/2013005-01 NCV Failure to Perform a Survey on Water Leak (Section 2RS6)
- 05000458/2013005-02 NCV Failure to Periodically Update the Updated Safety Analysis Report (Section 2RS8)
Closed
- 05000458/2013-001-00 LER Operations Prohibited by Technical Specifications for Operations with a Potential to Drain the Reactor Vessel (Section 4OA3)
TI 2515/182 TI Review of Industry Initiative to Control Degradation of Underground Piping and Tanks (Section 4OA5)