IR 05000333/2015002
| ML15203A190 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/21/2015 |
| From: | Arthur Burritt Reactor Projects Branch 2 |
| To: | Brian Sullivan Entergy Nuclear Northeast |
| Burritt A | |
| References | |
| IR 2015002 | |
| Download: ML15203A190 (30) | |
Text
uly 21, 2015
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2015002
Dear Mr. Sullivan:
On June 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant. The enclosed inspection report documents the inspection results which were discussed on July 16, 2015, 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 Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
No findings were identified during this inspection.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs 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 component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-333 License No. DPR-59
Enclosure:
Inspection Report 05000333/2015002 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-333 License No. DPR-59 Report No. 05000333/2015002 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, NY Dates: April 1, 2015, through June 30, 2015 Inspectors: E. Knutson, Senior Resident Inspector B. Sienel, Resident Inspector N. Graneto, Operations Engineer C. Grimes, Health Physicist R. Rolph, Health Physicist Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000333/2015002; 04/01/2015 - 06/30/2015; James A. FitzPatrick Nuclear
Power Plant (FitzPatrick); Routine Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced and in-office inspections performed by regional inspectors. No findings were identified. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 5.
REPORT DETAILS
Summary of Plant Status
FitzPatrick began the inspection period at 100 percent power. On April 15, 2015, operators reduced power to 65 percent to perform a control rod sequence exchange, single control rod scram time testing, and turbine valve testing, and restored power to 100 percent. FitzPatrick remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors reviewed Entergys preparations for the onset of seasonal high temperatures. The review focused on the control room ventilation and reactor building ventilation systems. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the corrective action program (CAP) 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 Entergys seasonal weather 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 hot weather conditions. Documents reviewed for each section of this inspection report are listed in the
.
b. Findings
No findings were identified.
.2 Summer Readiness of Offsite and Alternate Alternating Current Power Systems
a. Inspection Scope
The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate alternating current (AC) power systems to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergys procedures affecting these areas and the communications protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Entergy established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system engineer, reviewing condition reports, and walking down portions of the offsite and AC power systems including the 115 kilovolt (kV) switchyard.
b. Findings
No findings were identified.
3. Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On May 20, 2015, the inspectors reviewed FitzPatricks preparations for high winds due to an arriving weather front. The inspectors walked down exterior portions of the plant to identify loose or inadequately protected equipment and materials. The inspectors verified that the circulating water and service water systems were operated in accordance with procedural requirements for high wind conditions. The plant did not experience any significant operational issues as a result of the high wind conditions.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdown (71111.04 - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
A residual heat removal (RHR) system during planned maintenance on the B RHR system on April 7, 2015 B core spray system during planned maintenance on the A core spray system on April 21, 2015 B standby gas treatment (SBGT) system during planned maintenance on the A SBGT system on April 22, 2015 B and D emergency diesel generators (EDGs) while A and C EDGs were inoperable due to planned maintenance on the A emergency service water (ESW)system and planned maintenance on the C EDG on May 18, 2015 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, TSs, condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors 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 CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
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 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.
West cable tunnel, fire area/zone IC/CT-1, on April 14, 2015 A train EDG and switchgear rooms, fire area/zones V/EG-1, EG-2, EG-5, on April 16, 2015 B train EDG and switchgear rooms, fire area/zones VI/EG-3, EG-4, EG-6, on April 16, 2015 West crescent, fire area/zone XVIII/RB-1W, on May 27, 2015 East and west electric bays, fire area/zone II/SW-2 and IC/SW-1, on June 9, 2015
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the B EDG jacket water heat exchanger performance to determine its readiness and availability to perform its safety function. This heat exchanger is cooled by the B ESW system. The inspectors reviewed the design basis for the component and verified Entergys commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment. The inspectors reviewed and discussed the results of the June 2015 heat exchanger inspection and testing with engineering staff. The inspectors verified that Entergy staff initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum allowable amount.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
(71111.11Q - 1 sample)
a. Inspection Scope
The inspectors observed licensed operator simulator training on May 5, 2015, which included a hostile action on site, a steam leak from the reactor core isolation cooling (RCIC) system, a condensate system leak that led to the loss of all condensate and feedwater, an anticipated transient without scram, and emergency depressurization. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency 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.
Additionally, the inspectors assessed the ability of the training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
(71111.11Q - 1 sample)
a. Inspection Scope
On April 15, 2015, the inspectors observed control room operators during a control rod sequence exchange which required a reactor downpower to approximately 65 percent.
The inspectors observed crew briefs, reactivity manipulations using control rods and the reactor water recirculation system, and single control rod scram time testing. The inspectors observed crew performance to verify that procedure use, crew communications, and coordination of activities between work groups met established expectations and standards.
b. Findings
No findings were identified.
.3 Annual Review of Examination Results
a. Inspection Scope
On June 4, 2015, one NRC region-based inspector conducted an in-office review of results of Entergy-administered annual operating tests for 2015, for Fitzpatrick operators (the biennial requalification written examination will not be administered in 2015). The inspection assessed whether Pass/Fail rates were consistent with the guidance of IMC 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP). The review verified that the failure rate (individual or crew)did not exceed 20 percent.
3 out of 44 operators failed at least one section of the Annual Exam. The overall individual failure rate was 6.8 percent.
0 out of 6 crews failed the simulator test. The crew failure rate was 0.0 percent.
b. Findings
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, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, and maintenance rule basis documents to ensure that Entergy staff 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 Title 10 of the Code of Federal Regulations (10 CFR)50.65 and verified that the (a)(2) performance criteria established by Entergy staff was reasonable. 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.
Automatic depressurization system Reactor vessel Control room ventilation
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work. The inspectors reviewed whether risk assessments were performed as required by 10 CFR 50.65(a)(4),and were accurate and complete. When emergent work was performed, the inspectors reviewed whether plant risk was promptly reassessed and managed. The inspectors also walked down selected areas of the plant which became more risk significant because of the maintenance activities to ensure they were appropriately controlled to maintain the expected risk condition. The reviews focused on the following activities:
Planned B RHR system maintenance during the week of April 6, 2015 Planned A core spray system and A SBGT system maintenance during the week of April 20, 2015 Planned C EDG maintenance during the week of May 18, 2015 Planned B EDG maintenance during the week of June 1, 2015 Planned 115 kV offsite line 4 maintenance, including FitzPatrick tie breaker 10012 and reserve station service transformer 71T-3, during the week of June 22, 2015
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
CR-JAF-2015-02139 concerning the operability of emergency core cooling and RCIC equipment in the east crescent with a tube leak in east crescent unit cooler 66UC-22D, on May 6, 2015 CR-JAF-2015-01294 concerning the operability of three Target Rock 3-stage safety relief valves currently in use at FitzPatrick, based on new information from the vendor, on May 21, 2015 CR-JAF-2015-00789 concerning the raised reactor fuel support piece for cell 38-39, based on new vendor analysis of the condition, on May 26, 2015 CR-JAF-2015-01718 and Event Notification#50979 concerning the effect of a control room door that was found not to be able to latch on the operability of the control room envelope, on June 2, 2015 CR-JAF-2015-02748 concerning the effect of unsatisfactory fuel oil sample results on the operability of the B EDG, on June 25, 2015 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 TS 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 TSs and UFSAR to Entergy staffs 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 by Entergy staff. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Permanent Modification - Security Electrical System
a. Inspection Scope
The inspectors evaluated a modification to the security electrical system implemented by engineering change (EC) 18195, Upgrade the Security Systems Electrical Generator -
Security Upgrade Project and Removal of 99UPS7 / 99UPS8, Revision 2. Specifically, this EC was initially implemented to install an upgraded security electrical generator, which was previously completed. Revision 2 to the EC was added to eliminate uninterruptable power supplies 99UPS7 and 99UPS8 due to obsolescence issues, by transferring their loads to 99UPS9 and 99UPS10 (also installed earlier under this modification).
Additionally, the modification added new transformers and new transfer switches to allow security loads to be supplied by multiple sources and therefore increase reliability.
The inspectors reviewed EC 18195, including the component classification checklist, the post-modification test plan, and the process applicability determination, to verify that the modification did not degrade the performance capability of the security electrical system.
The inspectors discussed the modification with design engineering staff and walked down accessible portions of the modification.
b. Findings
No findings were identified.
.2 Permanent Modification - C EDG Oil System
a. Inspection Scope
The inspectors evaluated a modification to the C EDG lube oil system implemented by EC 50781, Replace hard piping with flex hose for the EDG circulating & turbocharger lube oil pumps. This EC was implemented to mitigate pump to motor coupling degradation through the installation of flexible hose in place of hard piping on the suction and discharge piping.
The inspectors reviewed EC 50781, which was the parent EC for all four EDGs, and EC 55962 issued for the C EDG, including the process applicability determination and the post maintenance test results, to verify that the modification did not degrade the performance capability of the EDG. The inspectors also observed the installation of the modification and performed a post-installation walkdown of the modification.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
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.
Work Order (WO) 52548802-02 to clean and inspect B and D RHR service water pump discharge strainer basket #1 on April 8, 2015 WO 52257594 to overhaul and install the A core spray pump breaker on April 21, 2015 WO 00411723 to perform B rod block monitor alarm troubleshooting and repair on April 22, 2015 WO 52488197 to perform C EDG electrical preventive maintenance on May 21, 2015 WO 52286384 to perform C EDG forced paralleling panel preventive maintenance on May 21, 2015 WO 52422120-03 to replace the A/C-EDG tie breaker 71-10504 on May 21, 2015 WO 52490309 to perform eddy current testing on the B EDG jacket water heat exchanger on June 9, 2015
b. Findings
No findings were identified.
1R22 Surveillance Testing
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 TSs, the UFSAR, and station 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:
ST-2XB, RHR Service Water Loop B Quarterly Operability Test (IST [inservice test]),
on April 9, 2015 ISP-175B1, Reactor and Containment Cooling Instrument Functional Test/Calibration (ATTS [analog transmitter trip system])**, on April 14, 2015 RAP-7.4.01, Control Rod Scram Time Evaluation**, on April 15, 2015 ST-3JA, Core Spray Initiation Logic System A Functional Test, on April 20, 2015 ST-24J, RCIC Flow Rate and Inservice Test (IST), on April 27, 2015 ST-4N, HPCI [high pressure coolant injection] Quick Start, Inservice, and Transient Monitoring Test (IST), on May 4, 2015 SP-01.02, Reactor Water Sampling and Analysis, on June 3, 2015
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine FitzPatrick emergency drill on June 18, 2015, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operating facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the facilities and combined drill critiques to compare inspector observations with those identified by FitzPatrick staff in order to verify whether the FitzPatrick staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
.2 Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on May 5, 2015, which required Emergency Plan implementation by an operations crew. Entergy staff planned for this evolution to be evaluated and included in performance indicator (PI)data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. 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 ensure that Entergy evaluators noted the same issues and entered them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed Entergy staffs performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR 20, TSs, applicable Regulatory Guides (RGs), and the procedures required by TSs as criteria for determining compliance.
Radiological Hazard Assessment The inspectors reviewed recent plant radiation surveys and any changes to plant operations since the last inspection to identify any new radiological hazards for onsite workers or members of the public.
Instructions to Workers The inspectors observed several containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements.
Radiological Hazards Control and Work Coverage The inspectors evaluated in-plant radiological conditions and performed independent radiation measurements during facility walkdowns and observations of radiological work activities. The inspectors assessed whether posted surveys, radiation work permits, worker radiological briefings, and the use of continuous air monitoring and dosimetry monitoring were consistent with the present conditions. The inspectors examined the control of highly activated or contaminated materials stored within the spent fuel pool and the posting and physical controls for selected high radiation areas (HRAs), locked HRAs, and very high radiation areas (VHRAs) to verify conformance with the occupational PI.
Risk-Significant HRA and VHRA Controls The inspectors reviewed the controls and procedures for HRAs, VHRAs, and radiological transient areas in the plant.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG-0041, TSs, and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring systems associated with airborne radioactivity controls and respiratory protection equipment staged for emergency use. The inspectors also reviewed respiratory protection program procedures and current PIs for unintended internal exposure incidents.
Engineering Controls The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airborne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm setpoints.
Use of Respiratory Protection Devices The inspectors reviewed the adequacy of Entergy staffs use of respiratory protection devices in the plant to include applicable as low as reasonably achievable (ALARA)evaluations, respiratory protection device certification, respiratory equipment storage, air quality testing records, and individual qualification records.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors reviewed the monitoring, assessment, and reporting of occupational dose.
The inspectors used the requirements in 10 CFR 20, applicable RGs, TSs, and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed radiation protection program audits, National Voluntary Laboratory Accreditation Program dosimetry testing reports, and procedures associated with dosimetry operations.
Internal Dosimetry The inspectors reviewed internal dosimetry procedures, whole body counter measurement sensitivity and use, adequacy of the program for whole body count monitoring of plant radionuclides, adequacy of the program for dose assessments based on air sample monitoring and the use of respiratory protection, and internal dose assessments for any actual internal exposures.
Special Dosimetric Situations The inspectors reviewed Entergy staffs external dose monitoring of workers in large dose rate gradient environments, and dose assessments performed since the last inspection that used multi-badging, skin dose, or neutron dose assessments.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program
a. Inspection Scope
The inspectors reviewed the radiological environmental monitoring program (REMP) to validate the effectiveness of the radioactive gaseous and liquid effluent release program.
The inspectors used the requirements in 10 CFR 20, 40 CFR 190, 10 CFR 50 Appendix I, TSs, the Offsite Dose Calculation Manual (ODCM), and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed Entergys 2013 and 2014 annual radiological environmental and effluent monitoring reports, REMP program audits, ODCM changes, land use census, and inter-laboratory comparison program results.
Onsite Inspection The inspectors reviewed and/or observed the following items:
Sample collection, monitoring, and dose measurement stations (e.g.,
thermoluminescent dosimeter, air monitoring, vegetation, milk)
Calibration and maintenance records for air sample and dosimetry measurement equipment Environmental sampling of the effluent release pathways specified in the ODCM Meteorological tower and meteorological data readouts Meteorological instrument operability status and calibration results Missed and/or anomalous environmental samples identified, resolved, and reported in the annual radioactive environmental monitoring report Positive environmental sample assessment results The groundwater monitoring program as it applies to selected potential leaking SSCs 10 CFR 50.75(g) records of leaks, spills, and remediation since the previous inspection Changes to the ODCM due to changes to the land use census, long-term meteorological conditions, and/or modifications to the environmental sample stations Environmental sample laboratory analysis results, and measurement detection sensitivities Results of the laboratory quality control program audit, and the inter- and intra-laboratory comparison program results
b. Findings
No findings were identified
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Reactor Coolant System Specific Activity and Reactor Coolant System Leak Rate
a. Inspection Scope
The inspectors reviewed Entergys submittals for the reactor coolant system (RCS)specific activity and RCS leak rate PIs for the period of April 1, 2014, through March 31, 2015. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI)
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7.
The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the PI. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate (first quarter 2015), and chemistry personnel taking and analyzing an RCS sample.
b. Findings
No findings were identified.
.2 Radiological Effluent TS/ODCM Radiological Effluent Occurrences
a. Inspection Scope
The inspectors reviewed Entergy staffs submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the first quarter 2014 through the fourth quarter 2014. The inspectors used PI definitions and guidance contained in NEI Document 99-02, Revision 7, to determine if the PI data was reported properly. The inspectors reviewed the public dose assessments for the PI for public radiation safety to determine if related data was accurately calculated and reported.
The inspectors reviewed the CAP database to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated offsite dose calculations to determine if indicator results were accurately reported.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy staff entered issues into the CAP 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 CAP and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review (1 sample)
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the CAP, such as trend reports, PIs, system health reports, and CAP backlogs.
The inspectors also reviewed Entergys CAP database for the first and second quarters of 2015 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Entergys Aggregate Performance Review Meeting (APRM) Reports for the fourth quarter of 2014 and first quarter of 2015, conducted under EN-LI-121, Trending and Performance Review Process, to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of CRs generated over the course of the past two quarters by departments that provide input to the quarterly Aggregate Performance Review. The inspectors determined that, in most cases, the issues were appropriately evaluated by Entergy staff for potential trends and resolved within the scope of the CAP.
For example, the inspectors noted that radiation worker practices were being tracked as adverse trends in the fourth quarter 2014 and first quarter 2015 APRM reports, consistent with the inspectors assessment. Similarly, the inspectors noted that emergency plan vehicle and telephone equipment issues were identified as improvement items in the first quarter 2015 APRM report.
.3 Annual Sample: Unclear Basis for In-Use Temporary Modification (1 sample)
a. Inspection Scope
The inspectors performed an in-depth review of Entergys cause analysis and corrective actions associated with CR-JAF-2015-01309 concerning the apparent use of a non-current safety evaluation as the technical bases for an in-use temporary modification.
Specifically, when the inspectors originally reviewed Temporary Modification EC 53770, Change Setpoint from 250°F to 300°F for CRD [control rod drive] Temperature Alarm (Up to 10), on March 17, 2015, they noted that the temporary modification package did not include the technical bases for the change. Instead, it appeared to rely on JAF-SE-00-030, Allowance of Temporary Setpoint Adjustment of Individual CRD Temperature Alarms, to provide the technical basis. The inspectors noted that JAF-SE-00-030 had been written in June 2000 and had not been maintained current. At the time of discovery, EC 53770 was in-use on CRD 38-39. The inspectors discussed this issue with FitzPatrick staff, who had indicated that the basis document would be updated. The issue was entered into the CAP as CR-JAF-2015-01309.
The inspectors assessed Entergys problem identification threshold, cause analyses, extent-of-condition reviews, compensatory actions, and the prioritization and timeliness of Entergys corrective actions to determine whether Entergy staff was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergys CAP and the plants TSs.
b. Findings and Observations
No findings were identified.
The inspectors reviewed completed CR-JAF-2015-01309 and found that no action had been taken to update JAF-SE-00-030. The corrective action that had been originally assigned was to update that evaluation to support the subject temporary modification.
However, the response to this action had been to generate a new action to, . . . update and/or take corrective actions to address as necessary. The result was an evaluation that concluded that no revision was required.
The inspectors discussed this issue with FitzPatrick staff. The staff explained that reference to JAF-SE-00-030 in the temporary modification package had actually not been necessary, because allowance to perform the alarm setpoint adjustment had previously been incorporated in the FSAR. Therefore, separate technical justification was not required.
The inspectors concluded that FitzPatrick staffs corrective action for this issue was technically correct and, to that extent, that the CAP had been effective.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On July 16, 2015, the inspectors presented the inspection results to Mr. Brian Sullivan, Site Vice President, and other members of the FitzPatrick 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
- B. Sullivan, Site Vice President
- C. Adner, Manager, Regulatory Assurance
- B. Benoit, Manager, Systems and Components Engineering
- W. Drews, Manager, Design and Program Engineering
- R. Heath, Manager, Radiation Protection
- J. Jones, Manager, Emergency Planning
- S. McAllister, Director, Regulatory and Performance Improvement
- T. Peter, Manager, Operations
- D. Poulin, Director, Engineering
- T. Redfearn, Manager, Security
- M. Reno, Manager, Training
- S. Vercelli, General Manager, Plant Operations
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
None