IR 05000461/2014001

Annual Assessment Letter for Clinton Power Station, Unit 1, (Report 05000461/2014001)

ML15062A577
Person / Time
Site:	Clinton
Issue date:	03/04/2015
From:	Boland A Division Reactor Projects III
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2014001
Download: ML15062A577 (8)

Text

UNITED STATES rch 4, 2015

SUBJECT:

ANNUAL ASSESSMENT LETTER FOR CLINTON POWER STATION, UNIT 1 (Report 05000461/2014001)

Dear Mr. Hanson:

On February 12, 2015, the U.S. Nuclear Regulatory Commission (NRC) staff completed its end-of-cycle performance review of Clinton Power Station, Unit 1. The NRC reviewed the most recent quarterly performance indicators in addition to inspection results and enforcement actions from January 1, 2014 through December 31, 2014. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined that the performance at Clinton Power Station, Unit 1, for the first quarter of 2014 was within the Regulatory Response Column of the Reactor Oversight Process Action Matrix based on all inspection findings being classified as having very low safety significance (i.e., Green) and one performance indicator (PI) requiring additional NRC oversight (i.e., White).

Specifically, the Unplanned Scrams per 7000 Critical Hours PI crossed the Green-White threshold and caused Clinton Unit 1 to transition from the Licensee Response Column to the Regulatory Response Column of the Action Matrix in the fourth quarter of 2013. The NRC informed you of this transition in a letter dated February 5, 2014 (ADAMS Accession Number ML14037A328).

The NRC completed a supplemental inspection per Inspection Procedure 95001 for the White PI on July 28, 2014, as documented in our letter to you dated August 28, 2014 (ADAMS Accession Number ML14240A522). Since the PI had returned to Green in the second quarter of 2014, the PI is considered a Green Action Matrix input since the second quarter of 2014 in accordance with Inspection Manual Chapter 0305.

However, the NRC determined that, Clinton Power Station, Unit 1, during the most recent quarter was within the Regulatory Response Column of the NRCs Reactor Oversight Process (ROP) Action Matrix because of one or more greater-than-green Security cornerstone inputs as described in our letter to you dated October 23, 2014. Clinton Power Station transitioned to the Regulatory Response Column of the Reactor Oversight Process Action Matrix beginning the second quarter of 2014. The NRC informed you of this transition in a letter dated October 28, 2014 (ADAMS Accession Number ML14302A082). Therefore, in addition to ROP baseline inspections, the NRC conducted a supplemental inspection in accordance with Inspection Procedure (IP) 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area to review the actions taken to address the security issue.

The enclosed inspection plan lists the inspections scheduled through June 30, 2016. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence.

From August 11, 2014 through August 28, 2014, the International Atomic Energy Agency (IAEA)

completed an independent assessment of your stations performance. This assessment team is called an Operational Safety Review Team, or OSART. The focus of the review by OSART is on the safety and reliability of the plant through a review of plant operations and performance of the licensees management and staff. During this inspection period, licensee personnel debriefed the NRC resident inspectors about issues identified by the OSART assessment team on a daily basis. The NRC staff also reviewed both a draft and final version of the OSART report (ADAMS Accession Number ML15062A115). Based on the results of the our review and assessment of the scope of OSART activities through the daily and weekly debriefs and the review of the draft and final OSART mission report, the NRC concluded that a one-time inspection credit is appropriate in accordance with Inspection Manual Chapter 2515, Section 08.05, Baseline Inspection Credit for Operational Safety Review Team Effort, dated October 18, 2013. The full detail of the inspection credit is provided in the enclosed crediting plan.

The NRC plans to conduct infrequently performed inspection activities related to the operation of the Independent Spent Fuel Storage Installation using IP 60853, On-Site Fabrication of Components and Construction of an ISFSI, IP 60854.1, Preoperational Testing of an Independent Spent Fuel Storage Facility Installations at Operating Plants, and IP 60856 and IP 60856.1, Review of 10 CFR 72.212(b) Evaluations.

From January 1 to December 31, 2014, the NRC issued three Severity Level IV traditional enforcement violations associated with impeding the regulatory process. Therefore, the NRC plans to conduct IP 92723, Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period to follow-up on these violations.

Additionally, an NRC audit of licensee efforts towards compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, and Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" is ongoing. This audit includes an onsite component in order for the NRC to evaluate mitigating strategies as described in licensee submittals, and to receive and review information relative to associated open items. This onsite activity will occur in the months prior to the first unit at each site achieving compliance with the Orders, and will

aid staff in development of a Safety Evaluation for the site. The onsite component at your site has been scheduled for the week of March 9, 2015. A site-specific audit plan for the visit has been provided in advance to allow sufficient time for preparations.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact Gregory Roach at 630-829-9731 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Anne T. Boland, Director Division of Reactor Projects Docket No. 50-461 License No. NPF-62 Enclosures:

1. Clinton OSART Inspection Crediting Plan 2. Clinton Power Station Inspection/Activity Plan cc w/encl: Distribution via LISTSERV

ML15062A577 Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME Rng:rj GRoach ABoland DATE 03/04/15 03/03/15 03/03/15

CLINTON OSART INSPECTION CREDITING PLAN The following inspection procedure credit will be provided for Clinton Power Station, Unit 1.

Inspection Procedure Inspection Comments Credit IP 71111.22 25% Full credit is given. Four inspection Surveillance Testing samples will not be performed in 2015.

IP 71111.05AQ 25% Full credit is given. One inspection Fire Protection sample will not be performed per quarter for 2015.

IP 71124.01 25% Full credit is given in the form of Radiological Hazard Assessment reduced inspection effort.

and Exposure Controls IP 71124.02 25% Full credit is given in the form of Occupational ALARA Planning and reduced inspection effort.

Controls IP 71124.03 25% This inspection module had been In-Plant Airborne Radioactivity completed for this biennial cycle. Full Control and Mitigation credit will be given next cycle in the form of reduced inspection effort.

IP 71124.04 25% This inspection module had been Occupational Dose Assessment completed for this biennial cycle. Full credit will be given next cycle in the form of reduced inspection effort.

IP 71124.05 25% This inspection module had been Radiation Monitoring completed for this biennial cycle. Full Instrumentation credit will be given next cycle in the form of reduced inspection effort.

IP 71124.06 25% Full credit is given in the form of Radioactive Gaseous and Liquid reduced inspection effort.

Effluent Treatment IP 71124.07 25% This inspection module had been Radiological Environmental completed for this biennial cycle. Full Monitoring Program credit will be given next cycle in the form of reduced inspection effort.

IP 71124.08 25% Full credit is given in the form of Radioactive Solid Waste Processing reduced inspection effort.

and Radioactive Material Enclosure 1

Inspection Procedure Inspection Comments Credit IP 71114.03 50% This inspection module had been Emergency Response Organization completed for the biennial cycle. Full Staffing and Augmentation System credit will be given next cycle in the form of reduced inspection effort.

IP 71114.05 50% This inspection module had been Maintenance of Emergency completed for the biennial cycle. Full Preparedness credit will be given next cycle in the form of reduced inspection effort.

IP 71152B 50% Full credit is given in the form of Problem Identification and reduced inspection effort.

Resolution For the radiation protection areas, several inspection procedures have already been performed for the current biennial period. Therefore credit will be given for these procedures in the next biennial cycle. For the emergency preparedness areas, both inspection procedures had already been performed and completed for the current biennial cycle. Therefore credit will be given for these procedures in the next cycle.

Page 1 of 2 Clinton 03/03/2015 07:31:34 Inspection / Activity Plan Report 22 03/01/2015 - 06/30/2016 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site BI MODS - MODIFICATIONS /50.59 3 1 03/02/2015 03/20/2015 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications ISFSI - PAD CONSTRUCTION 1 1 03/01/2015 06/30/2015 IP 60853 On-Site Fabrication Of Components And Construction On An ISFSI OL PREP - INIT EXAM/MARCH 2015 3 1 03/09/2015 03/13/2015 W90326 OL - INITIAL EXAM - 2015 MAR-APR - CLINTON OL EXAM - INIT EXAM/MARCH 2015 3 1 03/16/2015 03/27/2015 W90326 OL - INITIAL EXAM - 2015 MAR-APR - CLINTON BI ISI - ISI INSPECTION 1 1 04/27/2015 05/22/2015 IP 7111108G Inservice Inspection Activities - BWR BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 05/04/2015 05/08/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls PI&R - BIENNIAL PI&R INSPECTION 4 1 08/10/2015 08/28/2015 IP 71152B Problem Identification and Resolution BI OLRQ - BIENNIAL REQUALPROGRAM INSPECTION 2 1 06/08/2015 06/12/2015 IP 7111111B Licensed Operator Requalification Program ISFSI - ISFSI PREOP TESTING AND PLANS 2 1 07/01/2015 08/31/2015 IP 60854.1 Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants ISFSI - ISFSI 72.212 REVIEW 2 1 08/01/2015 08/31/2015 IP 60856 Review of 10 CFR 72.212(b) Evaluations ISFSI - INITIAL LOADING INSPECTION 2 1 09/01/2015 12/31/2015 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 10/26/2015 10/30/2015 IP 71124.02 Occupational ALARA Planning and Controls BI EPEX - EP EXERCISE / PI VERIFICATION 1 1 11/16/2015 11/20/2015 IP 7111407 Exercise Evaluation - Hostile Action (HA) Event 1 11/16/2015 11/20/2015 IP 7111408 Exercise Evaluation - Scenario Review 1 11/16/2015 11/20/2015 IP 71151 Performance Indicator Verification BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 11/30/2015 12/04/2015 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment 1 11/30/2015 12/04/2015 IP 71151 Performance Indicator Verification TI 191 - TI 191 MITIGATING STRATEGIES 2 1 01/01/2016 03/31/2016 IP 2515/191 Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & EP Info Request March 12, 2012 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Clinton 03/03/2015 07:31:34 Inspection / Activity Plan Report 22 03/01/2015 - 06/30/2016 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site CDBI - COMPONENT DESIGN BASES INSPECTION 6 1 01/25/2016 02/26/2016 IP 7111121 Component Design Bases Inspection BI RP - RADIATION PROTECTION BASELINE INSPECTION 2 1 03/14/2016 03/18/2016 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1 03/14/2016 03/18/2016 IP 71124.02 Occupational ALARA Planning and Controls 1 03/14/2016 03/18/2016 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1 03/14/2016 03/18/2016 IP 71124.04 Occupational Dose Assessment ENG BI - INSERVICE INSPECTION 1 1 05/08/2016 05/29/2016 IP 7111108G Inservice Inspection Activities - BWR This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.