IR 05000286/2011005
| ML12039A294 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/08/2012 |
| From: | Mel Gray Reactor Projects Branch 2 |
| To: | Ventosa J Entergy Nuclear Operations |
| Gray M | |
| References | |
| IR-11-005 | |
| Download: ML12039A294 (35) | |
Text
UNITED STATES N UCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000286/201 1 005
Dear Mr. Ventosa:
On December 31 ,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 3. The enclosed integrated inspection report documents the inspection results, which were discussed on January 19,2012, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's 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, no findings were identified.
ln accordance with 10 CFR 2.390 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 NRC Public Document Room of from the Publicly Available Records component of the NRC's Document System (ADAMS). ADAMS is accessible from the NRC website at http://rarww.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/ftl ,fr*,I Mel Gray, Chief Reactor Projects Bfanch 2 Division of Reactor Projects Docket No. 50-286 License No. DPR-26
Enclosure:
lnspection Report 05000286/201100s
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000286/201 1 005
Dear Mr. Ventosa:
On December 31 ,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 3. The enclosed integrated inspection report documents the inspection results, which were discussed on January 19,2012, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's 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, no findings were identified.
In a
REGION I Docket No.: 50-286 License No.: DPR-26 Report No.: 05000286/2011005 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: Indian Point Nuclear Generating Unit 3 Location: 450 Broadway, GSB Buchanan, NY 1051 1-0249 Dates: October 1,2011 through December 31, 2011 Inspectors: P. Cataldo, Senior Resident Inspector - lndian Point 3 M. Halter, Resident Inspector - Indian Point 3 T. Fish, Senior Operations Engineer - Region 1 J. Furia, Senior Health Physicist - Region 1 E. Gray, Senior Reactor Inspector - Region 1 J. Nicholson, Health Physicist - Region 1 J. Noggle, Senior Health Physicist - Region 1 Approved By: Mel Gray, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
lR 05000286120110Q5; 1011111-12131111; Indian Point Nuclear Generating (lndian Point) Unit 3;
Resident Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
REPORT DETAILS
Summarv of Plant Status Indian Point Unit 3 operated at or near 100 percent power for the inspection period.
1, REACTORSAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 1 sample)
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of activities to prepare Indian Point for the onset of seasonal low temperatures. The review focused on the auxiliary boiler feed pump building, the intake structure, the fire protection water system, and the control building.
The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Entergy's seasonalweather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of the inspection report are listed in the Attachment.
b. Findinos No findings were identified.
1R04 EquipmentAliqnment
.1 Partial Svstem Walkdowns (71111.04Q
- 3 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
.
33 auxiliary boiler feed pump returned to service on October 27,2011
.
31 and 33 service water pumps (SWPs)during 32 SWP outage on December 12, 2011 o 32 residual heat removal (RHR) returned to service following testing on December 16,2011 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance and their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b.
Findinqs No findings were identified.
.2 Full Svstem Walkdown (71111.04S
- 1 sample)
a. Inspection Scope
On November 3, 2011, the inspectors performed a complete system walkdown of accessible portions of the Unit 3 auxiliary feedwater system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Entergy appropriately evaluated and resolved any deficiencies.
b. Findinqs No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterlv Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy staff controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
.
Emergency Diesel Generator (EDG) service water (SW) valve room fire zone (FZ)-36A on October 5,2011
.
Charging pump #31 (FZ-s) on October 27 , 2011
.
Charging pump #32 (FZ-6) on October 27, 2Q11 o Charging pump #33 (FZ-7) on October 27,2011 b.
Findinqs No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed and evaluated a fire brigade drill scenario conducted on December 20, 2011 . The drill scenario involved a simulated fire on the 15' elevation of the turbine building, which also included mitigation of a hydrazine-fueled fire, The inspectors evaluated the readiness of the plant fire brigade to fight fires and included a verification that Entergy personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions, as required.
The inspectors evaluated specific attributes as follows:
.
Proper wearing of turnout gear and self-contained breathing apparatus
.
Proper use and layout of fire hoses
.
Employment of appropriate fire-fighting techniques
.
Sufficient fire-fighting equipment brought to the scene
.
Effectiveness of command and control r Propagation of the fire into other plant areas
.
Smokeremovaloperations
.
Utilization of pre-planned strategies
.
Adherence to the pre-planned drill scenario o Drillobjectives met The inspectors also evaluated the fire brigade's actions to determine whether these actions were in accordance with Entergy's fire-fighting strategies.
b. Findinqs No findings were identified.
1R11 Licensed Operator Reoualification Proqram
.1 Quarterlv Review of Licensed Operator Requalification Testino and Traininq
(71111.11Q - 1 sample)a.
Insoection Scope The inspectors observed licensed operator simulator training on October 20,2011, which included implementation of 3-ONOP-TG-3, Rapid Shutdown. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal operating procedures.
The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the technical specification action statements entered by the control room supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
Findinqs No findings were identified.
.2 Licensed Operator Requalification (71111.118 - 1 sample)
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, lnspection Procedure Attachment71111.1 1, "Licensed Operator Requalification Program," Appendix A, "Checklist for Evaluating Facility Testing Material" and Appendix B, "Suggested Interview Topics."
A review was conducted of recent operating history documentation found in inspection reports, licensee event reports, Entergy's corrective action program, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from Entergy's corrective action program which indicated possible training deficiencies to verify that they had been appropriately addressed. These reviews did not identify any operational events that were indicative of possible training deficiencies.
The operating tests for the week of September 12-16, 2011, were reviewed for quality and performance.
On December 12,2011, the results of the written exam and annual operating tests for year 2011 were reviewed to determine if pass/fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix l, "Operator Requalification Human Performance Significance Determination Process. "
The review verified the following:
.
Crew pass rate was greater than 80 percent. (Pass rate was 100 percent.)
o Individual pass rate on the dynamic simulator test was greater than 80 percent.
(Pass rate was 96 percent.)
.
lndividual pass rate on the written exam was greater than 80 percent.
(Pass rate was 100 percent.)
o lndividual pass rate on the job performance measures of the operating exam was greater than 80 percent. (Pass rate was 100 percent.)
r More than 75 percent of the individuals passed all portions of the exam. (96 percent of the individuals passed all portions of the examination.)
Observations were made of the dynamic simulator exams and job performance measures (JPM) administered during the week of Septpmber 12-16,2A11. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of five JPMs.
The remediation plan for an individual's written exam failure was reviewed to assess the effectiveness of the remedial training.
Operators, instructors, and training/operation's management were interviewed for feedback on their training program and the quality of training received.
Simulator performance and fidelity were reviewed for conformance to the reference plant control room.
A sample of records for requalification training attendance, program feedback, reporting, and medical examinations were reviewed for compliance with license conditions, including NRC regulations.
b.
Findin$
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)
- (2) performance criteria established by Entergy staff was reasonable. As applicable, for SSCs classified as (a) (1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a) (2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred, within and across maintenance rule system boundaries.
o DS-416 breaker failure-to-close on August 19,2011 o 138 kV primary pilot wire circuit issues; ground mat testing on October 6-7, 2011
.
(aX3) periodic evaluation on November 21, 2011 b.
Findinqs No findings were identified.
1R13 Maintenance Risk Assessments and Emerqent Work Control (71111
.13 - 3 samples)
a. Insoection Scope The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy personnel performed the appropriate risk assessments prior to removing equipment for work, The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)
- (a) and that the assessments were accurate and complete. When Entergy staff performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
o Elevated risk during 3-PT-M13A1 and PCV-1276 maintenance on October 11,2Q11 o Elevated risk during SI-MOV - 889A, TCV-130, and 34 isophase fan maintenance, 3-PC-R01B, and control rods in manualon October 18,2011 o Elevated risk during 3-PT-A29E, 3-PC-R74A, 3-PC-OL3828, 34 SWP maintenance, and control rods in manual on October 19.2011 b. Findinqs No findings were identified.
1R15 Operabilitv Determinations and FunctionalitvAssessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
o 32 SW pump zurn strainer on October 1, 2011
.
34 SW pump delta-P out of tolerance on October 19, 2011 r Nitrogen pressure regulator, PCV-1276, for the nitrogen backup to air operated valves in the auxiliary feedwater system on November 17,2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Entergy's evaluations to determine whether the components or systems were operable, 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 evaluations.
b.
Findinqs No findings were identified.
1R19 PostMaintenance Testinq
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
.
AFW Nitrogen backup system, RV-1284 replacement, on October 13,2011
.
32 spent fuel pit pump mechanical seal replacement, returned on October 17 , 2011
.
RC-AOV-519 on November 1, 2011
.
MS-PCV-1131 on November 8,2011 o 32 charging pump suction valve and seal replacement, returned on November 10, 2011 b. Findinqs No findings were identified.
1R22 Surveillance Testino
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Entergy procedure requirements, The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions.
The inspectors reviewed the following surveillance tests:
.
3-PT-Q027, Stroke Test of Containment lsolation Valves PCV-1234, -1235, -1236, and -1237, on October 1, 2011
.
31 EDG overspeed test on October 4,2011
.
3-PT-Q87C, Reactor Coolant Temperature Channel 41 Functional Test, on October 13,2411
.
3-PT-Q92D,34 Service Water Pump In-Service Test, on October 19 - 20,2011 b.
Findinqs No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational/Public Radiation Safety
2RS2 Occupational As Low As is Reasonablv Achievable Planninq qnd Controls
a. Inspection Scope
Radioloqical Work Planninq Based on radiation work permit outage work activity collective exposure results from the Unit 3 Spring 2011 refueling outage, the inspectors selected for review those work activities that resulted in a dose of five person-rem or greater. This review included the basis of the exposure estimates with reference to historical performance metrics, and exposure mitigation requirements planned for these outage tasks.
With respect to the outage work activity samples, the inspectors compared the actual exposure results with the estimated exposure established in Entergy's As Low As is Reasonably Achievable (ALARA) plans for these work activities. The inspectors also compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the work activity person-hour actual results, to evaluate the performance results. The inspectors determined the reasons (e.9.,
failure to adequately plan the activity, failure to provide sutficient work controls)for any inconsistencies between intended and actual work activity doses. The inspectors also determined if any identified exposure overrun causes were identified and entered into Entergy's corrective action program.
Verification of Dose Estimates and Exposure Trackino Svstems The Unit 3 Spring refueling outage ALARA work packages that resulted in greater than five person-rem were reviewed to include the assumptions and basis (including dose rate and man-hour estimates) for their collective exposure estimates, Applicable procedures were reviewed to determine the methodology for estimating exposures for specific work activities and determining the intended dose outcome.
The inspectors verified for the selected work activities that Entergy personnel established measures to track, trend, and if necessary reduce, occupational doses for ongoing work activities and that criteria were established to prompt additional reviews and/or additional ALARA planning and controls.
The inspectors evaluated Entergy's method of adjusting exposure estimates when unexpected changes in scope or emergent work were encountered. The inspectors determined if adjustments to exposure estimates (intended dose) were based on sound radiation protection and ALARA principles or if they were only adjusted to account for inadequate work control.
b. Findinqs No findings were identified.
2RS8 Radioactive Solid Waste Processino and Radioactive Material Handlino. Storaqg-and
Transoortqlion (7 1 124.08 - 1 sample)a.
lnspwtion Scope The inspectors reviewed the solid radioactive waste system description in the updated final safety analysis report (UFSAR), the Process Control Program (PCP), 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 (QA) audits in this area since the last inspection to gain insights into Entergy's performance and inform the "smart sampling" inspection planning.
The inspectors selected areas where containers of radioactive waste were stored, and verified that the containers were labeled in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 20.1904, "Labeling Containers," or controlled in accordance with 10 CFR 20.1905, "Exemptions to Labeling Requirements," as appropriate.
The inspectors verified that radioactive materials storage areas were controlled and posted in accordance with the requirements of 10 CFR Part20, "Standards for Protection against Radiation." For materials stored or used in the controlled or unrestricted areas, the inspectors verified that they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1 801 , "Security of Stored Material," and 10 CFR 20.1802, "Control of Material not in Storage," as appropriate.
The inspectors verified that Entergy staff established a process for monitoring the impact of longterm storage (e.9., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements. The inspectors selected containers of stored radioactive materials, and verified that there were no signs of swelling, leakage, and deformation.
The inspectors selected liquid and solid radioactive waste processing systems, and walked down accessible portions of systems to verify and assess that the current system configuration and operation agreed with the descriptions in the UFSAR, offsite dose calculation manual and PCP.
The inspectors selected radioactive waste processing equipment that was not operational and/or was abandoned in place, and verified that Entergy staff had established administrative and/or physical controls to ensure that the equipment would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure. The inspectors verified that Entergy staff 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 any changes made to the radioactive waste processing systems since the last inspection. The inspectors verified that changes from what is described in the UFSAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate.
The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, 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 verified that the tank recirculation procedure provided for sufficient mixing.
The inspectors verified that Entergy's PCP correctly described the current methods and procedures for dewatering and waste.
The inspectors selected radioactive waste streams, and verified that Entergy's radiochemical sample analysis results were sufficient to support radioactive waste characterization as required by 10 CFR Part 61 , "Licensing Requirements for Land Disposal of Radioactive Waste." The inspectors verified that Entergy's use of scaling factors and calculations, to account for difficult-to-measure radionuclides, was technically sound and based on current 10 CFR Part 61 analysis.
For the waste streams selected above, the inspectors verified that 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) verify that waste shipments continued to meet the requirements of 10 CFR Part 61 .
The inspectors verified that Entergy personnel established and maintained an adequate QA program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61
.55 and 10 CFR 61.56, "Waste Characteristics."
The inspectors observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation and receipt activities. The inspectors determined that the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to Entergy's response to NRC Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial,"
dated August 10, 1979, and 49 CFR Part 172,"Hazardous Materials TabJe, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans," Subpart H, "Training." The inspectors verified that Entergy's training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.
The inspectors selected non-excepted package shipment records and verified that the shipping documents indicated the proper shipper name; emergency response information and a Z4-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.
The inspectors verified that problems associated with radioactive waste processing, handling, storage, and transportation were being identified by Entergy statf at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the Entergy corrective action program. The inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by Entergy staff that involved radioactive waste processing, handling, storage, and transportation.
The inspectors reviewed the results of selected audits performed since the last inspection of this program and evaluated the adequacy of Entergy's corrective actions for issues identified during those audits.
b.
Findinqs No findings were identified.
OTHER ACTIVITIES
4OA1 Performance lndicator Verification
(7 1 151)
.1 Reactor Coolant Svstem (RCS) Leak Rate (1 sample)
a. Inspection Scope
The inspectors reviewed Entergy's submittal for the RCS leak rate performance indicators for the period of October 1,2010, through September 30,2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEl)
Docu ment 99-A2, "Regulatory Assessment Performa nce lndicator G uideline, "
Revision 6. The inspectors also reviewed control room logs of daily measurements for RCS leakage and compared that information to the data reported by the performance indicator.
b. Inspection Findings No findings were identified.
.2 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspectors reviewed implementation of Entergy's Occupational Exposure Control Effectiveness Performance lndicator Program. Specifically, the inspectors reviewed Condition Reports (CRs) and radiological controlled area dosimeter exit logs for the past four calendar quarters (through 3rd quarter 2011). These records were reviewed for occurrences involving locked high radiation areas, very high radiation areas, and unpfanned exposures against the criteria specified in NEI 99-02, Regulatory Assessment Performance lndicator Guideline, Revision 6, to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators.
Inspection Findinqs No findings were identified.
.3 Radiogctive Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiolosical Effluent Occurrences (1 sample)
a. Inspection Scope
The inspectors reviewed a listing of relevant effluent release reports for the past four calendar quarters (through 3rd quarter 2011), for issues related to the public radiation safety performance indicator, which measures radiological effluent release occurrences per site that exceed 1.5 mrem/quarter whole body or 5.0 mrem/quarter organ dose for liquid effluents; 5.0 mrads/quarter gamma air dose, 10 mrad/quarter beta air dose, and 7.5 mrads/quarter for organ dose for gaseous effluents. The review was against applicable criteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The purpose of the review was to verify that occurrences that met the NEI criteria were recognized and identified as Performance Indicator occurrences.
The inspectors reviewed the following documents to ensure Entergy met all requirements of the performance indicator:
.
Monthly projected dose assessment results due to radioactive liquid and gaseous effluent releases
.
Quarterly projected dose assessment results due to radioactive liquid and gaseous effluent releases
.
Dose assessment procedures b. lnspection Findinos No findings were identified.
4c.A2 Problem ldentification and Resolution (71152 - 2 samples)
.1 Routine Review of Problem ldentification and Resolution Activities
Inspection Scooe As required by Inspection Procedure71152, "Problem ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy personnel entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings, b. Findinos No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, "Problem ldentification and Resolution," to identify trends that might indicate the existence of more significant safety issues, ln this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Entergy's corrective action program database for the third and fourth quarters of 2411, to assess condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report review (Section 4042.1). The inspectors reviewed Entergy's quarterly trend report for the second quarter of 2Q11, as well as inputs for the third quarter trend report for the Chemistry and Radiation Protection departments, conducted under EN-LI-121 , Entergy Trending Process, to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findinqs and Observations No findings were identified.
The inspectors reviewed a sample of departmental inputs into the third quarter trend report, which included the Chemistry and Radiation Protection departments. This review included a sample of issues and events that occurred over the course of the past two quarters to objectively determine whether issues were appropriately considered or ruled as emerging or adverse trends, and in some cases, verified the appropriate disposition of resolved trends. The inspectors verified that these issues were addressed within the scope of the corrective action program, or through department review and documentation in the quarterly trend report for overall assessment, 7117 While the inspectors did not identify any adverse trends that were not already identified within Entergy's CAP and the quarterly trend reports, the inspectors evaluated the status of a trend identified during a previous inspection. In particular, the inspectors evaluated Entergy's progress in resolution of an NRC inspection finding documented in CR-IP2-2011-04541associated with corrosion identified on Unit 3 SW piping characterized in the CAP as significance level "D." According to EN-Ll-102, "Corrective Action Process",
significance level"D" indicates that the condition identified
- (1) has been documented and corrected, and no further corrective actions are warranted, or
- (2) is identified as a straightfonruard condition that can be closed to a work order or another condition report, or
- (3) is below the level of an adverse condition as defined in the CAP. Subsequently, the inspectors noted that Entergy identified a large population of open Level "D" work orders (Priority 4 or greater) associated with safety-related equipment. The inspectors concluded that Entergy personnel made substantial progress in determining the appropriate priority of work orders associated with safety-related equipment to ensure a more timely resolution.
.3 Annual Sample: Review of the Operator Workaround Program
a. Inspection Scooe The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Entergy procedure OAP-45, "Operator Burden Program."
The inspectors reviewed Entergy's process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent Entergy self assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.
b. Findinos and Observations No findings were identified.
The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.
The inspectors also verified that Entergy entered operator workarounds and burdens into the corrective action program at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.
4043 Follow-Up of Events and Notices of Enforcement Discretion (71 153 - 1 sample)
(Closed) Licensee Event Report (LER) 05000286/2011-003-00: Technical Specification Required Shutdown and a Safety System Functional Failure for a Leaking Service Water Pipe Causing Flooding in the Service Water Valve Pit Preventing Access for Accident Mitigation On February 22,2011, flooding occurred in a SW valve pit that contained conventional essential and non-essential SW header isolation valves. The flooding was caused by corrosion from a leaking 1O-inch SW pipe, and required a plant shutdown in accordance with Technical Specification 3.0,3, when Entergy operators determined valves in the pit, which at the time were inaccessible from the flooding, were required to mitigate design basis accidents. The inspectors reviewed the condition and associated root cause evaluation under CR-lP3-2011-00680, and noted that the cause was related to an inadequate coating repair performed on this piping section in 1992. The inspectors concluded that while a missed opportunity from 2006 was identified during the root cause evaluation, it was not considered reasonably within Entergy's ability to foresee and correct, based on the circumstances. Entergy personnel installed a temporary repair and subsequently replaced the degraded section of piping during the Spring 2011 refueling outage. In addition, Entergy staff implemented extent-of-condition inspections on both units, revised the applicable portions of Entergy's SW program as it relates to inspection, maintenance and repair of SW piping. The event was previously assessed for technical specification compliance, risk significance, and other attributes under baseline Inspection Procedure 71153, as well as the performance indicator process and documented in NRC lnspection Report No. 0500028612011002. No new issues were revealed by the LER. This LER was closed during an onsite review.
4045 Other Activities
1. On-Site Fabrication of Components for an Independent Spent Fuel Storaqe Installation
flsFSr) (60853)
a. Inspection Scope
ln 2Q10, the Unit 3 fuel storage building (FSB) crane was upgraded to single failure proof in accordance with criteria in NUREG-0554. The Unit 3 FSB crane would be used as part of the process to transfer spent fuel from the Unit 3 spent fuel pool (SFP) to the Unit 2 SFP for placement into dry storage containers. Entergy previously submitted a license amendment request to the NRC to allow the transfer of spent fuel from the Unit 3 SFP to the Unit 2 SFP. That request is under review by the NRC.
During the week of November 7,2011, the inspectors reviewed the readiness of the Unit 3 FSB crane. This included a review of the lifting sequence, operator qualification records, and condition reports. The crane factory test procedure, crane electrical calculation, FSB evaluation under revised loads, the crane seismic analysis and other crane related calculations were also reviewed. Radiological controls for the crane operator and spotter were discussed with a team of Radiation Protection personnel. The inspectors performed a walkdown of the Unit 3 FSB crane, including the crane controls.
The inspectors also reviewed Entergy's Compliance Matrix for NUREG-0554 and NOG-1 that have comparisons of requirements for a single failure proof crane to the crane characteristics.
b.
Findinos No findings were identified.
2. Operation of an ISFSI at Operatinq Plants (60855.1)
Inspection Scope The inspectors verified by direct observation and independent evaluation that Entergy personnel performed loading activities at the ISFSI in a safe manner and in compliance with applicable procedures. The inspectors toured the ISFSI and reviewed radiological surveys performed during the past 12 months.
b. Findinqs No findings were identified.
40A6 Meetinos, Includinq Exit On January 19, 2012, the inspectors presented the inspection results to Mr. John Ventosa, Site Vice President, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Ventosa, Site Vice President
- B. Allen, Engineering
V, Andreozzi, Systems Engineering Supervisor
- N. Azevedo, Engineering Programs Manager
- R. Burroni, Systems Engineering Manager
- L. Coyle, General Manager, Plant Operations
- G. Dahl, Licensing Specialist
- J. DeFrancesco, Project Manager
- J. Dinelli, Site Operations Manager
- M. Dreis, System Engineer
- L. Lubrano, System Engineer
- T. McKee, Requalification Program Administrator
- R. Miller, Assistant Project Manager
- F. Mitchell, Health Physicist
- R. Robenstein, Simulator Supervisor
- J. Skonieczny, Senior Project Engineer
- S. Stevens, RP Supervisor
- R. Tagliamonte, Radiation Protection Manager
- M. Tesoriero, Programs and Components Engineering Manager
- B. Walpole, Licensing Manager
- R. Waters, Licensing
- W. Wittich, Engineering
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Closed
- 05000286/2011-003-00 LER Technical Specification Required Shutdown and a Safety System Functional Failure for a Leaking Service Water Pipe Causing Flooding in the Service Water Valve Pit Preventing Access for Accident Mitigation