IR 05000461/2013003
| ML13211A275 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/30/2013 |
| From: | Christine Lipa NRC/RGN-III/DRP/B1 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-13-003 | |
| Download: ML13211A275 (48) | |
Text
uly 30, 2013
SUBJECT:
CLINTON POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000461/2013-003
Dear Mr. Pacilio:
On June 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station. The enclosed report documents the inspection results, which were discussed on July 2, 2013, with Mr. B. Taber and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, one self-revealed finding of very low safety significance was identified. The finding was determined to involve a violation of NRC requirements.
Because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating the above self-revealed violation as a Non-Cited Violation consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the Non-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Clinton Power Station. In addition, 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 III, and the NRC Resident Inspector at Clinton Power Station. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Document 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/
Christine A. Lipa, Branch Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62 cc w/encl: Distribution via ListServ'
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-461 License No: NPF-62 Report No: 05000461/2013-003 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station, Unit 1 Location: Clinton, IL Dates: April 1 through June 30, 2013 Inspectors: B. Kemker, Senior Resident Inspector D. Lords, Resident Inspector S. Bell, Health Physicist J. Draper, Reactor Engineer D. McNeil, Senior Operations Engineer V. Myers, Health Physicist R. Walton, Senior Operations Engineer B. Winter, Reactor Inspector S. Mischke, Resident Inspector, Illinois Emergency Management Agency Approved by: C. Lipa, Chief Branch 1 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000461/2013-003, 04/01/13 - 06/30/13, Clinton Power Station, Unit 1,
Radiological Hazard Assessment and Exposure Controls.
This report covers a three-month period of inspection by the resident inspectors and announced baseline inspections by regional inspectors. One Green finding, which had an associated Non-Cited Violation, was identified. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011.
Cross-cutting aspects are determined using IMC 0310, Components within the Cross Cutting Areas, dated October 28, 2011. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Occupational Radiation Safety
- Green.
A self-revealing finding of very low safety significance (Green) and associated Non-Cited Violation of Technical Specification 5.4.1.a for the failure to follow procedures associated with the Radiation Work Permit (RWP) on March 28, 2013. The issue resulted in the unplanned intake of radioactive material by five workers.
RWP 10014553, 2013 RW HRA/LHRA, Revision 0, established the requirement for the usage of high efficiency particulate air vacuums during the cleanup of a legacy radioactive resin spill. The licensee replaced this cleanup method with manual resin removal during the cleanup contrary to the conditions set in the RWP. This is a performance deficiency, which was within the licensees ability to foresee and should have been prevented. The issue was entered into the licensees corrective action program as Action Request 01494203. The licensee completed actions to ensure worker compliance with radiation protection program procedures.
The performance deficiency was determined to be more than minor safety significance in accordance with Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation, in that, the workers received additional and unplanned dose from the intake of radioactive materials.
The significance was determined in accordance with IMC 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process. The inspectors determined the finding has very low safety significance (Green) because the finding did not involve: (1) As Low As Reasonably Achievable (ALARA) planning or work controls involving excessive occupational collective dose, (2) an overexposure, (3) a substantial potential for overexposure, or (4) compromised ability to assess dose. The primary cause of this finding was related to the cross-cutting aspect of human performance with the component of decision making. The licensee failed to use conservative assumptions in decision making and failed to adopt a requirement to demonstrate that the proposed action is safe in order to proceed. H.1(b). (Section 2RS1.1)
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
Summary of Plant Status
Clinton Power Station (CPS), Unit 1 was operated at or near full power during the inspection period with the following exceptions:
- On April 26, 2013, Control Room operators manually scrammed the reactor from full power following an unexpected electro-hydraulic control (EHC) system oil leak from a connection to one of the main turbine control valves. Following repairs, the unit was restarted on April 27th, synchronized to the grid on April 29th, and returned to full power April 30th.
- On May 19th, the licensee reduced power to about 75 percent to perform control rod sequence exchanges and main turbine control/stop/intermediate valve and main steam isolation valve (MSIV) testing. The unit was returned to full power later the same day.
- On May 21st, the licensee reduced power to about 75 percent to perform control rod sequence exchanges and repair a steam leak on a feed water heater drain valve. The unit was returned to full power the following day.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate AC [Alternating Current] Power Systems
a. Inspection Scope
The inspectors evaluated the licensees plant features and procedures for operation and continued availability of offsite and alternate AC power systems. The inspectors interviewed plant personnel and reviewed the licensees communications protocols between the Transmission System Operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Aspects considered in the inspectors review included:
- The actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant will not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;
- The compensatory actions identified to be performed if it is not possible to predict the post-trip voltage at the plant for the current grid conditions;
- The required re-assessment of plant risk based on maintenance activities that could affect grid reliability, or the ability of the transmission system to provide offsite power; and
- The required communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power is challenged.
The inspectors performed a walkdown of the switchyard with a plant maintenance engineer to observe the material condition of the offsite power sources. The inspectors also reviewed the status of outstanding work orders to assess whether corrective actions for any degraded conditions were scheduled with the TSO with the appropriate priority.
This inspection constituted one offsite and alternate AC power systems readiness inspection sample as defined in Inspection Procedure (IP) 71111.01.
b. Findings
No findings of significance were identified.
.2 Readiness For Impending Hot Summer Weather Conditions
a. Inspection Scope
The inspectors evaluated the licensees preparations for hot summer weather conditions, focusing on the electrical distribution system and the plant chilled water system.
During the weeks of April 15th and April 22nd, the inspectors performed a detailed review of severe weather and plant de-winterization procedures and performed general area plant walkdowns. The inspectors focused on plant-specific design features and implementation of procedures for responding to or mitigating the effects of hot summer weather conditions on the operation of the plant. The inspectors reviewed system health reports and system engineering summer readiness review documents for the above systems.
Additionally, the inspectors verified that adverse weather related issues were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests (ARs) were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted one seasonal extreme weather readiness inspection sample as defined in IP 71111.01.
b. Findings
No findings of significance were identified.
.3 External Flooding
a. Inspection Scope
The inspectors reviewed flood protection barriers and procedures for coping with external flooding at the plant. Clinton Power Station has limited susceptibility to external flooding as described in Section 3.4.1.1 of the Updated Final Safety Analysis Report (UFSAR) and Section 5.2 of the Individual Plant Examination for External Events Report.
The inspectors reviewed CPS 4303.02, Abnormal Lake Level, Revision 12a, to assess the adequacy of the licensee response to external flooding conditions.
The inspectors conducted a walkdown of the Lake Screen House, including the shutdown service water pump rooms. The inspectors assessed the condition of water tight door seals; the sealing of equipment floor plugs, electrical conduits, holes or penetrations in floors and walls between the pump rooms; and the condition of room floor drains, sumps, and sump pumps. In addition, the inspectors conducted a walkdown of the Clinton Lake Dam with the cognizant plant engineer to assess the condition of the dam and the readiness of materials staged to mitigate high water levels.
Additionally, the inspectors verified that external flooding protection issues were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted one external flooding readiness inspection sample as defined in IP 71111.01.
b. Findings
No findings of significance were identified.
.4 Readiness For Impending Adverse Weather Condition - Tornado/High Winds
a. Inspection Scope
Since thunderstorms with potential tornados and high winds were forecast in the vicinity of CPS for the week of April 22nd, the inspectors reviewed the licensees overall preparations for the expected conditions. The inspectors toured the plant grounds in the vicinity of the main power transformers, unit auxiliary transformers, reserve auxiliary transformers, emergency reserve auxiliary transformer, and static volt-amp reactive compensators to look for loose debris, which if present could become missiles during a tornado or with high winds. During the inspection, the inspectors focused on plant-specific design features and the licensees procedure used to respond to tornado and high winds conditions.
This inspection constituted one readiness for impending adverse weather condition inspection sample as defined in IP 71111.01.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- Residual Heat Removal (RHR) Train A during planned maintenance on RHR Train B;
- Spent Fuel Pool Cooling (FC) Train B during planned maintenance on FC Train A; and
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones. The inspectors reviewed operating procedures, system diagrams, Technical Specification (TS) requirements, and the impact of ongoing work activities on redundant trains of equipment. The inspectors verified that conditions did not exist that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components were aligned correctly and available as necessary.
In addition, the inspectors verified that equipment alignment problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted three partial system walkdown inspection samples as defined in IP 71111.04.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Routine Resident Inspectors Tours
a. Inspection Scope
The inspectors performed fire protection tours in the following plant areas:
- Fire Zone T-1j, Steam Jet Air Ejector Room - Elevation 7810
- Fire Zone A-3e, Containment Electrical Penetration (West) Area -
Elevation 7620
- Fire Zone T-1c, Condensate Pump Room - Elevation 7090
- Fire Zone F-1a, General Access Area - Elevation 7120
- Fire Zone D-4, Division 3 Diesel Generator Room - Elevation 7370; and
- Fire Zone R-1k, Clean and Dirty Oil Storage Room - Elevation 7370 The inspectors verified that transient combustibles and ignition sources were appropriately controlled and assessed the material condition of fire suppression systems, manual firefighting equipment, smoke detection systems, fire barriers and emergency lighting units. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; that the licensees fire plan was in alignment with actual conditions; and that fire doors, dampers, and penetration seals appeared to be in satisfactory condition.
In addition, the inspectors verified that fire protection related problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted six quarterly fire protection inspection samples as defined in IP 71111.05AQ.
b. Findings
No findings of significance were identified.
1R06 Flooding Protection Measures
.1 Internal Flooding
a. Inspection Scope
The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the service water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant areas to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:
- Control and Diesel Generator Buildings - Elevation 7020 This inspection constituted one internal flooding inspection sample as defined in IP 71111.06.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
.1 Annual Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the licensees examination of the RHR A heat exchanger. The inspectors assessed the as-found and as-left condition of the heat exchanger by direct observation and document reviews to verify that no deficiencies existed that would adversely impact the heat exchangers ability to transfer heat to the shutdown service water system and to ensure that the licensee was adequately addressing problems that could affect the performance of the heat exchanger. The inspectors observed portions of inspection and cleaning activities, eddy current tube examination activities, and reviewed documentation to verify that the inspection acceptance criteria specified in procedure ER-AA-340-1002, Service Water Heat Exchanger and Component Inspection Guide, Revision 5 were satisfactorily met.
This inspection constituted one annual heat sink inspection sample as defined in IP 71111.07.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
The inspectors observed licensed operators during simulator training on May 15th. The inspectors assessed the operators response to the simulated events focusing on alarm response, command and control of crew activities, communication practices, procedural adherence, and implementation of Emergency Plan requirements. The inspectors also observed the post-training critique to assess the ability of licensee evaluators and operating crews to self-identify performance deficiencies. The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.
This inspection constituted one quarterly licensed operator requalification program simulator inspection sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
a. Inspection Scope
On May 19th, the inspectors observed licensed operators in the Control Room perform control rod sequence exchanges and main turbine control/stop/intermediate valve and MSIV testing. These activities required heightened awareness, additional detailed planning, and involved increased operational risk. The inspectors evaluated the following areas:
- Licensed operator performance;
- Crews clarity and formality of communications;
- Ability to take timely actions in the conservative direction;
- Prioritization, interpretation, and verification of annunciators alarms;
- Correct use and implementation of procedures;
- Control panel manipulations;
- Oversight and direction from supervisors; and
- Ability to identify and implement appropriate TS actions.
This inspection constituted one quarterly licensed operator heightened activity/risk inspection sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
.3 Annual Operating Test Results
a. Inspection Scope
The inspectors reviewed the overall pass/fail results of the Annual Operating Test administered by the licensee from May 6th through June 7th, required by 10 CFR 55.59(a). The results were compared to the thresholds established in Inspection Manual Chapter (IMC) 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP)," to assess the overall adequacy of the licensees Licensed Operator Requalification Training (LORT) program to meet the requirements of 10 CFR 55.59. (02.02)
IP 71111.11, Section 02.02, Biennial Written Examination Pass/Fail Results, was not performed during this inspection. This inspection did not constitute an inspection sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
.4 Biennial Review
a. Inspection Scope
The following inspection activities were conducted during the week of June 3rd, to assess:
- (1) the effectiveness and adequacy of the facility licensees implementation and maintenance of its Systems Approach to Training (SAT) based LORT Program, put into effect to satisfy the requirements of 10 CFR 55.59;
- (2) conformance with the requirements of 10 CFR 55.46 for use of a plant-referenced simulator to conduct operator licensing examinations and for satisfying experience requirements; and
- (3) conformance with the operator license conditions specified in 10 CFR 55.53.
- Licensee Requalification Examinations (10 CFR 55.59(c); SAT Element 4 as Defined in 10 CFR 55.4): The inspectors reviewed the licensees program for development and administration of the LORT biennial written examination and annual operating tests to assess the licensees ability to develop and administer examinations that are acceptable for meeting the requirements of 10 CFR 55.59(a).
- The inspectors conducted a detailed review of twelve Job Performance Measures (JPMs) and six dynamic simulator scenarios to assess content, level of difficulty, and quality of the operating test materials. (02.04)
- The inspectors observed the administration of the annual operating test to assess the licensees effectiveness in conducting the examination(s),including the conduct of pre-examination briefings, evaluations of individual operator and crew performance, and post-examination analysis. The inspectors evaluated the performance of one crew in parallel with the facility evaluators during two dynamic simulator scenarios, and evaluated various licensed crew members concurrently with facility evaluators during the administration of several JPMs. (02.05)
- The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the last requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans. (02.07)
- Conformance with Examination Security Requirements (10 CFR 55.49):
The inspectors conducted an assessment of the licensees processes related to examination physical security and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests. The inspectors reviewed the facility licensees examination security procedure, and observed the implementation of physical security controls (e.g., access restrictions and simulator input/output controls) and integrity measures (e.g.,
security agreements, sampling criteria, bank use, and test item repetition)throughout the inspection period. (02.06)
- Conformance with Operator License Conditions (10 CFR 55.53): The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators, and which control room positions were granted watch-standing credit for maintaining active operator licenses. Additionally, medical records for twelve licensed operators were reviewed for compliance with 10 CFR 55.53(I). (02.08)
- Conformance with Simulator Requirements Specified in 10 CFR 55.46:
The inspectors assessed the adequacy of the licensees simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements. The inspectors reviewed a sample of simulator performance test records (e.g., transient tests, malfunction tests, scenario based tests, post-event tests, steady state tests, and core performance tests), simulator discrepancies, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy corrective action process to ensure that simulator fidelity was being maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics. (02.09)
- Problem Identification and Resolution (10 CFR 55.59(c); SAT Element 5 as Defined in 10 CFR 55.4): The inspectors assessed the licensees ability to identify, evaluate, and resolve problems associated with licensed operator performance (a measure of the effectiveness of its LORT program and their ability to implement appropriate corrective actions to maintain its LORT Program up-to-date). The inspectors reviewed documents related to licensed operator performance issues (e.g., recent examination and inspection reports including Cited and Non-Cited Violations; NRC End-of-Cycle and Mid-Cycle reports; NRC Plant Issue Matrix; Licensee Event Reports (LERs); and corrective action program documents, including documentation of plant events and review of industry operating experience). The inspectors also sampled the licensees quality assurance oversight activities, including licensee training department self-assessment reports. (02.10)
Inspection Procedure 71111.11, Section 02.03, Biennial Requalification Written Examination Quality, was not performed during this inspection. This inspection did not constitute an inspection sample as defined in IP 71111.11.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated the licensee's handling of selected degraded performance issues involving the following risk-significant structures, systems, and components (SSCs):
- AR 01444355, Division 1 DG Main Control Room Handswitch Failed to Shutdown DG;
- AR 01420045, 1PL12JA-86: Division 1 Lockout Relays Tripped Unexpectedly, and AR 01422698, Unexpected Trip of Division 1 DG; and
- AR 01496871, 5004-3H Self-Test System Failure Annunciator Received -
Unexpected.
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the SSCs. Specifically, the inspectors independently verified the licensee's handling of SSC performance or condition problems in terms of:
- Appropriate work practices;
- Identifying and addressing common cause failures;
- Scoping of SSCs in accordance with 10 CFR 50.65(b);
- Characterizing SSC reliability issues;
- Tracking SSC unavailability;
- Trending key parameters (condition monitoring);
- 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification; and
- Appropriateness of performance criteria for SSC functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSC functions classified (a)(1).
In addition, the inspectors verified that problems associated with the effectiveness of plant maintenance were entered into the licensee's corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted three maintenance effectiveness inspection samples as defined in IP 71111.12.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- Planned maintenance during the week of April 8-12 on Division 2 DG;
- Planned maintenance during the week of May 6-10 on RHR Train B;
- Planned maintenance during the week of June 10-14 on RHR Train C; and
- Emergent maintenance during the week of April 15-19 to troubleshoot Reactor Recirculation Pump B motor cooler leakage annunciator.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each of the above activities, the inspectors reviewed the scope of maintenance work in the plants daily schedule, reviewed Control Room logs, verified that plant risk assessments were completed as required by 10 CFR 50.65(a)(4) prior to commencing maintenance activities, discussed the results of the assessment with the licensees Probabilistic Risk Analyst and/or Shift Technical Advisor, and verified that plant conditions were consistent with the risk assessment assumptions. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify that risk analysis assumptions were valid, that redundant safety-related plant equipment necessary to minimize risk was available for use, and that applicable requirements were met.
In addition, the inspectors verified that maintenance risk related problems were entered into the licensees corrective action program with the appropriate significance characterization. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted four maintenance risk assessment inspection samples as defined in IP 71111.13.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- AR 01436642, Inadequate Deletion of Operations Requirements Manual Section Structural Integrity;
- AR 01489149, 1SX151C: Relief Valve Failed Allowable Range;
- AR 01483304, Mounting of Radiation Detectors Not Per Seismic Qualification;
- AR 01511406, 1RIX-PR034; Off-Gas Pretreat Monitor Spiking;
- AR 01458971, 1PL12JA; Division 1 DG Protective Relays Unsatisfactory As-found Testing; and, AR 01500132, 1PL12JB-87; Relay 287-DG1B As-found Testing Unsatisfactory; and
- EC 393439, Past Operability Support for Average Power Range Monitor Flow Gain Adjustments.
The inspectors selected these potential operability/functionality issues based on the risk significance of the associated components and systems. The inspectors verified that the conditions did not render the associated equipment inoperable or result in an unrecognized increase in plant risk. When applicable, the inspectors verified that the licensee appropriately applied TS limitations, appropriately returned the affected equipment to an operable status, and reviewed the licensees evaluation of the issue with respect to the regulatory reporting requirements. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluation. When applicable, the inspectors also verified that the licensee appropriately assessed the functionality of SSCs that perform specified functions described in the UFSAR, Operations Requirements Manual, Emergency Plan, Fire Protection Plan, regulatory commitments, or other elements of the current licensing basis when degraded or nonconforming conditions were identified.
In addition, the inspectors verified that problems related to the operability or functionality of safety-related plant equipment were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted six operability evaluation inspection samples as defined in IP 71111.15.
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Permanent Modifications
a. Inspection Scope
The inspectors reviewed the engineering analyses, modification documents, and design change information associated with the following permanent plant modification:
During this inspection, the inspectors evaluated the implementation of the design modification and verified, as appropriate, that:
- The compatibility, functional properties, environmental qualification, seismic qualification, and classification of materials and replacement components were acceptable;
- The structural integrity of the SSCs would be acceptable for accident/event conditions;
- The implementation of the modification did not impair key safety functions;
- No unintended system interactions occurred;
- The affected significant plant procedures, such as normal, abnormal, and emergency operating procedures, testing and surveillance procedures, and training were identified and necessary changes were completed;
- The design and licensing documents were either updated or were in the process of being updated to reflect the modification;
- The changes to the facility and procedures as described in the UFSAR were appropriately reviewed and documented in accordance with 10 CFR 50.59;
- The system performance characteristics, including energy needs affected by the modification continued to meet the design basis;
- The modification test acceptance criteria were met; and
- The modification design assumptions were appropriate.
Completed activities associated with the implementation of the modification, including testing, were also inspected, and the inspectors discussed the modification with the responsible engineering and operations staff.
This inspection constituted one permanent modification inspection sample as defined in IP 71111.18.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed post-maintenance testing for the following activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
Verify Proper Operation Main Control Room RCIC [Reactor Core Isolation Cooling] Flow Controller;
- WO 01482047-02, Operations PMT Run 1DG01KB Engine, Check for No Leakage;
- WO 01600569-05, Operations PMT Leak Check 1SX151C Relief Valve with Shutdown Service Water Pressure; and
- WO 01608078-04, Perform Post Maintenance Testing for Relays Installed in Control Room Ventilation B Chiller Control Panel.
The inspectors reviewed the scope of the work performed and evaluated the adequacy of the specified post-maintenance testing. The inspectors verified that the post-maintenance testing was performed in accordance with approved procedures; that the procedures contained clear acceptance criteria, which demonstrated operational readiness and that the acceptance criteria was met; that appropriate test instrumentation was used; that the equipment was returned to its operational status following testing; and, that the test documentation was properly evaluated.
In addition, the inspectors reviewed corrective action program documents associated with post-maintenance testing to verify that identified problems were entered into the licensee's corrective action program with the appropriate characterization. Selected action requests were reviewed to verify that the corrective actions were appropriate and implemented as scheduled.
This inspection constituted four post-maintenance testing inspection samples as defined in IP 71111.19.
b. Findings
No findings of significance were identified.
1R20 Refueling and Other Outage Activities
.1 Forced Outage C1F55
a. Inspection Scope
The inspectors evaluated outage activities during Unit 1 forced outage C1F55, which began on April 26th. Control Room operators manually scrammed the reactor from full power following an unexpected EHC oil leak from a connection to one of the main turbine control valves. After the unit was shut down, the licensee identified the oil leak was caused by a broken socket head cap screw used to attach a hydraulic shutoff valve to the turbine control valve with the three remaining cap screws loose. Following repairs, the unit was restarted on April 27th, synchronized to the grid on April 28th, and reached full power on April 30th.
The inspectors reviewed and evaluated the conduct of outage activities to ensure that the licensee considered risk in developing, planning, and implementing the forced outage schedule. The inspectors observed or reviewed plant equipment configuration and risk management, electrical lineups, startup activities, and identification and resolution of problems associated with the outage.
This inspection constituted one other outage inspection sample as defined in IP 71111.20.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following surveillance testing activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify that the testing was conducted in accordance with applicable procedural and TS requirements:
- CPS 0954.02, Reactor Core Isolation Cooling Valve Operability Checks, (Inservice Test);
- CPS 9432.63, CRVICS [Containment and Reactor Vessel Isolation Control System] Containment Building Exhaust Duct Radiation 1RlX-PR042C Channel Calibration, (Routine Test);
- CPS 9015.01, Standby Liquid Control Pump and Valve Operability, (Inservice Test); and
- CPS 9027.01C009, Remote Shutdown Panel Operability - Division 2 Checklist, (Routine Test).
The inspectors observed selected portions of the test activities to verify that the testing was accomplished in accordance with plant procedures. The inspectors reviewed the test methodology and documentation to verify that equipment performance was consistent with safety analysis and design basis assumptions, and that testing acceptance criteria were satisfied.
In addition, the inspectors verified that surveillance testing problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.
This inspection constituted two in-service tests and two routine surveillance tests for a total of four surveillance testing inspection samples as defined in IP 71111.22.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a full scale emergency preparedness drill on June 18th to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. This drill was planned to be evaluated and was included in performance indicator data regarding drill and exercise performance. The inspectors observed emergency response operations in the Outage Control Center and Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensees drill critique to compare any inspector-observed weaknesses with those identified by the licensees staff in order to evaluate the critique and to verify whether the licensees staff was properly identifying weaknesses and entering them into the corrective action program.
This inspection constituted one emergency preparedness drill evaluation inspection sample as defined in IP 71114.06.
b. Findings
No findings of significance were identified.
.2 Simulator Based Training Observation
a. Inspection Scope
The inspectors observed a simulator training evolution for the licensed operators on April 17th, which required Emergency Plan implementation by the operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the operators. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and to ensure that the licensees evaluators noted the same issues and entered them into the corrective action program.
This inspection constituted one emergency preparedness simulator-based training inspection sample as defined in IP 71114.06.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
2RS1 Radiological Hazard Assessment and Exposure Controls
The inspection activities supplement those documented in NRC Inspection Report 05000461/2013002 and constitute a partial sample as defined in IP 71124.01.
.0 Radiological Hazard Assessment (02.02)
a. Inspection Scope
The inspectors selected the following radiologically risk-significant work activities that involved exposure to radiation:
- Radioactive Resin Cleanup Activities.
For these work activities, the inspectors assessed whether the pre-work surveys performed were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the Radiological Survey Program to determine if hazards were properly identified, including the following:
- The identification of hot particles;
- The presence of alpha emitters;
- The potential for airborne radioactive materials, including the potential presence of transuranic and/or other hard-to-detect radioactive materials, (This evaluation may include licensee planned entry into non-routinely entered areas subject to previous contamination from failed fuel.);
- The hazards associated with work activities that could suddenly and severely increase radiological conditions and that the licensee has established a means to inform workers of changes that could significantly impact their occupational dose; and
- Severe radiation field dose gradients that can result in non-uniform exposures of the body.
b. Findings
Introduction:
A self-revealed finding of very low safety significance (Green) and associated Non-Cited Violation of TS 5.4.1.a for the failure to follow procedures resulted in the unplanned intake of radioactive material by five workers on March 28, 2013.
Description:
On March 28, 2013, licensee personnel initiated work to clean up a legacy radioactive resin spill in the 720 Radwaste Pipe Tunnel. Radiation Work Permit (RWP) 10014553, 2013 RW HRA/LHRA, Revision 0, was established for the work evolution. Work commenced with the workers performing the work wearing respiratory protection equipment and using high efficiency particulate air (HEPA) vacuums as the clean-up method. Midway through the clean-up the workforce took a break. At this time, a decision was made by the Radiation Protection (RP) Supervision to eliminate the respiratory protection equipment. This decision was based on the result of an air sample taken during non-work (break) period. The work recommenced with the workforce using HEPA vacuums with no respiratory protection equipment. Nearing the end of the clean-up, the usage of the HEPA vacuums became less effective due to the increasing lengths of hose installed on the vacuums. The RP Supervisor authorized the switch from HEPA vacuums to manual cleanup. The cleanup was completed by manually scooping up the resin and placement into containers.
Five workers received radiation monitor alarms when attempting to exit the Radiological Controlled Area or station portal monitors. These individuals where assayed for internal contamination using the stations whole body counter. The results showed positive for internal deposition of radioactive material. The station performed internal dose assessments in accordance with station procedures. All internal doses were determined to be less than 10 millirem.
Analysis:
The licensee established the requirement to use a HEPA vacuum in the RWP and its related Micro-ALARA Plan. These documents did not specify nor allow the usage of a manual cleanup method. The licensee established but did not follow the requirements for resin cleanup. This is a performance deficiency which was within the licensees ability to foresee and should have been prevented.
The performance deficiency was determined to be more than minor safety significance in accordance with Inspection IMC 0612, Appendix B, Issue Screening, because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation, in that, the workers received additional and unplanned dose from the intake of radioactive materials.
The significance was determined in accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process. The inspectors determined the finding has a very low safety significance (Green) because the finding did not involve:
- (1) ALARA planning or work controls involving excessive occupational collective dose,
- (2) an overexposure,
- (3) a substantial potential for overexposure, or
- (4) compromised ability to assess dose.
The primary cause of this finding was related to the cross-cutting aspect of human performance with the component of decision making. The licensee failed to use conservative assumptions in decision making and failed to adopt a requirement to demonstrate that the proposed action is safe in order to proceed in that licensee supervision did not ensure compliance with the approved RWP was maintained (H.1(b)).
Enforcement:
TS 5.4.1.a requires, in part, that written procedures be established, implemented and maintained in accordance with Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, Step 7(e) states the requirements for Radiation Protection procedures. Licensee procedure RP-AA-1008, Unescorted Access, and Conduct in Radiologically Controlled Areas, Revision 3, established the requirement to follow the RWP. Contrary to the above, on March 28, 2013, the licensee failed to ensure that RWP 10014553, 2013 RW HRA/LHRA, Revision 0 was followed. This resulted in the unplanned intake of radioactive materials by five workers. Since the violation of TS 5.4.1.a was of very low safety significance and was entered into the licensees corrective action program (AR 01494203) this violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000461/2013003-01, Failure to Follow Procedures Resulted in the Unplanned Intake of Radioactive Material by Five Workers).
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08) This inspection constituted one complete sample as defined in IP 71124.08.
.0 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the solid radioactive waste system description in the UFSAR, the Process Control Program, and the recent Radiological Effluent Release Report for information on the types, amounts, and processing of radioactive waste disposed.
The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensees performance and inform the smart sampling inspection planning.
b. Findings
No findings of significance were identified.
.1 Radioactive Material Storage (02.02)
a. Inspection Scope
The inspectors selected areas where containers of radioactive waste are stored, and evaluated whether the containers were labeled in accordance with 10 CFR 20.1904, Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to Labeling Requirements, as appropriate.
The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20, Standards for Protection against Radiation. For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, Security of Stored Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.
The inspectors evaluated whether the licensee established a process for monitoring the impact of long term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.
The inspectors selected containers of stored radioactive material, and assessed for signs of swelling, leakage, and deformation.
b. Findings
No findings of significance were identified.
.2 Radioactive Waste System Walkdown (02.03)
a. Inspection Scope
The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in the UFSAR, Offsite Dose Calculation Manual, and process control program.
The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment which is not in service or abandoned in place would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure.
The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, Changes, Tests, and Experiments.
The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes from what is described in the UFSAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate, and assessed the impact on radiation doses to members of the public.
The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the process control program, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, Waste Classification.
For those systems that provide tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing.
The inspectors assessed whether the licensees Process Control Program correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid).
b. Findings
No findings of significance were identified.
.3 Waste Characterization and Classification (02.04)
a. Inspection Scope
The inspectors selected the following radioactive waste streams for review:
- Concentrated Waste:
- Waste Sludge; and
- Spent Resin.
For the waste streams listed above, the inspectors assessed whether the licensees radiochemical sample analysis results (i.e., 10 CFR Part 61" analysis) were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated whether the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analyses for the selected radioactive waste streams.
The inspectors evaluated whether changes to plant operational parameters were taken into account to:
- (1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and
- (2) assure that waste shipments continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above.
The inspectors evaluated whether the licensee had established and maintained an adequate Quality Assurance Program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste Characteristics.
b. Findings
No findings of significance were identified.
.4 Shipment Preparation (02.05)
a. Inspection Scope
The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for cask loading and closure procedures were consistent with the vendors current approved procedures.
The inspectors assessed whether the shippers were knowledgeable of the shipping regulations and whether shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to:
- The licensees response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, dated August 10, 1979; and
- Title 49 CFR Part 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans, Subpart H, Training.
Due to limited opportunities for direct observation, the inspectors reviewed the technical instructions presented to workers during routine training. The inspectors assessed whether the licensees training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.
b. Findings
No findings of significance were identified.
.5 Shipping Records (02.06)
a. Inspection Scope
The inspectors evaluated whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number for the following radioactive shipments:
- Radioactive Material Shipment M12-018; Outage Equipment; February 24, 2012;
- Radioactive Waste Shipment W12-016; Spent Resin; October 11, 2012;
- Radioactive Waste Shipment W12-017; Dry Active Waste; October 30, 2012;
- Radioactive Waste Shipment W12-019; Fuel Pool Demineralizer Resin; December 27, 2012; and
- Radioactive Waste Shipment W13-003; Spent Resin; March 24, 2013.
Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation.
b. Findings
No findings of significance were identified.
.6 Identification and Resolution of Problems (02.07)
a. Inspection Scope
The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensee corrective action program. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation.
The inspectors reviewed results of selected audits performed since the last inspection of this program and evaluated the adequacy of the licensees corrective actions for issues identified during those audits.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Review of Submitted Quarterly Data
a. Inspection Scope
The inspectors performed a review of the data submitted by the licensee for the First Quarter 2013 Performance Indicators for any obvious inconsistencies prior to its public release in accordance with IMC 0608, "Performance Indicator Program."
This inspection was not considered to be an inspection sample as defined in IP 71151.
b. Findings
No findings of significance were identified.
.2 Mitigating Systems Performance Index (MSPI) - Cooling Water Systems
a. Inspection Scope
The inspectors reviewed a sample of plant records and data against the reported MSPI - Cooling Water Systems Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from July 2012 through March 2013, to validate the accuracy of the performance indicator data reported. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.
This inspection constituted one MSPI - Cooling Water System Performance Indicator verification inspection sample as defined in IP 71151.
b. Findings
No findings of significance were identified.
.3 Mitigating Systems Performance Index - Emergency AC Power System
a. Inspection Scope
The inspectors reviewed a sample of plant records and data against the reported MSPI -
Emergency AC Power System Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from April 2012 through March 2013, to validate the accuracy of the performance indicator data reported. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.
The inspectors also reviewed the licensees corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.
This inspection constituted one MSPI - Emergency AC Power System Performance Indicator verification inspection sample as defined in IP 71151.
b. Findings
No findings of significance were identified.
.4 Mitigating Systems Performance Index - High Pressure Injection Systems
a. Inspection Scope
The inspectors reviewed a sample of plant records and data against the reported MSPI - High Pressure Injection Systems Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from July 2012 through March 2013, to validate the accuracy of the performance indicator data reported. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.
This inspection constituted one MSPI - High Pressure Injection System Performance Indicator verification injection sample as defined in IP 71151.
b. Findings
No findings of significance were identified.
.5 Mitigating Systems Performance Index - Heat Removal System
a. Inspection Scope
The inspectors reviewed a sample of plant records and data against the reported MSPI - Heat Removal System Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from July 2012 through March 2013, to validate the accuracy of the performance indicator data reported. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.
The inspectors also reviewed the licensees corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.
This inspection constitutes one MSPI Heat Removal System Performance Indicator verification inspection sample as defined in IP 71151.
b. Findings
No findings of significance were identified.
.6 Mitigating Systems Performance Index - RHR System
a. Inspection Scope
The inspectors reviewed a sample of plant records and data against the reported MSPI - RHR System Performance Indicator. To determine the accuracy of the performance indicator data reported, performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the MSPI derivation reports, Control Room logs, Maintenance Rule database, LERs, and maintenance and test data from July 2012 through March 2013, to validate the accuracy of the performance indicator data reported. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.
The inspectors also reviewed the licensees corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this performance indicator.
This inspection constitutes one MSPI - RHR System Performance Indicator verification inspection sample as defined in IP 71151.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, they are not discussed in this report.
This inspection was not considered to be an inspection sample as defined in IP 71152.
b. Findings
No findings of significance were identified.
.2 Annual In-Depth Review Sample
a. Inspection Scope
The inspectors selected the following action request for in-depth review:
- AR 01510208; Multiple Troubles at 1PA06J, First Hit [Ground Monitoring]
Panel.
The inspectors verified the following attributes during their review of the licensee's corrective actions for the above action request and other related action requests:
- Complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;
- Consideration of the extent of condition, generic implications, common cause and previous occurrences;
- Evaluation and disposition of operability/reportability issues;
- Classification and prioritization of the resolution of the problem, commensurate with safety significance;
- Identification of the root and contributing causes of the problem; and
- Identification of corrective actions, which were appropriately focused to correct the problem.
The inspectors discussed the corrective actions and associated action request evaluations with licensee personnel.
This inspection constituted one annual in-depth review sample as defined in IP 71152.
b. Findings and Observations
No findings of significance were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion
.1 Reactor Scram Response
a. Inspection Scope
On April 26th, Unit 1 was manually scrammed from full power following an unexpected EHC system oil leak from a connection to one of the main turbine control valves. The inspectors responded to the Control Room to verify that post-scram plant parameters were as expected. The inspectors also reviewed plant procedures, equipment configurations, and Control Room logs. The inspectors verified that operator response was in accordance with plant procedures and that plant equipment responded as designed.
This inspection constituted one event follow-up inspection sample as defined in IP 71153.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
.1 Failure to Submit a Timely UFSAR Revision
By letter dated January 10, 2013, the licensee submitted Revision 15 of the UFSAR for Clinton Power Station, Unit 1 to the NRC. In accordance with 10 CFR 50.71, Maintenance of records, making reports, Paragraph (e); licensees are required to periodically submit updates to the UFSAR. Specifically, 10 CFR 50.71(e)(4) states, in part: Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months.
Upon review, the NRC staff found that the licensee did not submit Revision 15 of the UFSAR within the timeframe required by 10 CFR 50.71(e)(4). The last refueling outage at Clinton Power Station was completed on December 23, 2011, and Revision 14 of the UFSAR was submitted on January 10, 2011. Therefore, Revision 15 of the UFSAR was submitted 24 months (i.e., more than a year) after the last revision and more than 6 months after the last refueling outage. There was no approved exemption to the 6-month requirement for Clinton Power Station.
By letter dated April, 11, 2013, the NRC staff informed the licensee that its submittal of Revision 15 to the UFSAR did not meet the 10 CFR 50.71(e)(4) timeliness requirement (ADAMS Accession No. ML13099A426). The licensees failure to provide a timely update to the UFSAR constitutes a violation of minor safety significance that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The inspectors concluded that this violation was of minor safety significance because it did not screen as more-than-minor using the screening questions in IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening. The violation did not involve a failure to submit the required update to the UFSAR, but was simply a late submittal that had no adverse consequence. The licensee entered this violation into its corrective action program as AR 01502067.
.2 (Closed) Unresolved Item (URI)05000461/2012002-03, Incomplete ED [Electronic
Dosimeter] Dose Rate Alarm Evaluation The URI described a condition where additional information was needed by the inspectors to assess the licensees response to ED dose rate alarms caused by glove contamination. The inspectors previously reviewed this issue and documented a Non-Cited Violation of 10 CFR 20.1501(a) in NRC Inspection Report 05000461/2013002 for the licensees failure to perform surveys to ensure compliance with 10 CFR 20.1201 shallow-dose equivalent limits for five workers during the fourth quarter of 2011 due to contamination build-up on the workers gloves. This URI is closed.
4OA6 Management Meetings
.1 Resident Inspectors Exit Meeting
The inspectors presented the inspection results to Mr. B. Taber and other members of the licensees staff at the conclusion of the inspection on July 2, 3013. The licensee acknowledged the findings presented. Proprietary information was examined during this inspection, but is not specifically discussed in this report.
.2 Interim Exit Meetings
Interim exit meetings were conducted for:
- The Review of the Licensed Operator Requalification Program with Mr. B. Taber and other members of the licensees staff on June 7, 2013. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
- The Radiological Hazard Assessment and Exposure Controls; Radioactive Solid Waste Processing; Radioactive Material Handling, Storage, and Transportation Inspection with Mr. B. Taber and other members of the licensees staff on June 14, 2013. The licensee acknowledged the findings presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- G. Armstrong, Security Manager
- R. Bair, Shift Operations Superintendent
- K. Baker, Regulatory Assurance Manager
- R. Bedford, Licensed Operator Requalification Lead Training Instructor
- R. Campbell, RP Technical Manager
- J. Cunningham, Operations Director
- C. Dunn, Training Director
- R. Frantz, Regulatory Assurance
- M. Friedman, Radiation Protection Operations Manager
- N. Hightower, Radiation Protection Manager
- K. Leffel, Operations Support Manager
- D. Kemper, Engineering Director
- S. Kowalski, Senior Manager Design Engineering
- S. Mohundro, Engineering Programs Manager
- W. Noll, Site Vice President
- J. Peterson, Regulatory Assurance
- C. Rocha, Nuclear Oversight Manager
- R. Schenck, Work Management Director
- D. Shelton, Operations Services Manager
- D. Smith, Design Engineering
- J. Smith, Senior Manager Plant Engineering
- D. Snook, Operations Training Manager
- T. Stoner, Maintenance Director
- J. Stovall, Chemistry, Environmental & Radwaste Manager
- D. Szymkiewicz, Clinton Buried Piping Program Owner
- B. Taber, Plant Manager
- J. Ufert, Fire Marshall
- R. Zacholski, Nuclear Oversight Lead Assessor
Attachment
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000461/2013003-01 NCV Failure to Follow Procedures Resulted in the Unplanned Intake of Radioactive Material by Five Workers.
(Section 2RS1.1)
Closed
- 05000461/2013003-01 NCV Failure to Follow Procedures Resulted in the Unplanned Intake of Radioactive Material by Five Workers.
(Section 2RS1.1)
- 05000461/2012002-03 URI Incomplete ED Dose Rate Alarm Evaluation.
(Section 4OA5.2)
Discussed
None.
Attachment