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{{#Wiki_filter:UNITED STATES | {{#Wiki_filter:UNITED STATES ugust 5, 2011 | ||
SUBJECT: WATTS BAR NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000390/2011003 | ==SUBJECT:== | ||
WATTS BAR NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000390/2011003 | |||
==Dear Mr. Krich:== | ==Dear Mr. Krich:== | ||
On June 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Watts Bar Nuclear Plant, Unit 1. The enclosed integrated inspection report documents the inspection results which were discussed on July 6, 2011, with Mr. D. Grissette and other members of your staff. | On June 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Watts Bar Nuclear Plant, Unit 1. The enclosed integrated inspection report documents the inspection results which were discussed on July 6, 2011, with Mr. D. Grissette and other members of your staff. | ||
The inspection examined activities conducted under your license as they relate to safety and compliance with the | 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. | |||
TVA 2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice, | This report documents four NRC-identified findings of very low safety significance (Green). | ||
These findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Watts Bar facility. | |||
In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Watts Bar Nuclear Plant. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. | |||
TVA 2 In 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 or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
Sincerely, | Sincerely, | ||
/RA/ Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-390 License No.: NPF-90 | /RA/ | ||
Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-390 License No.: NPF-90 | |||
===Enclosure:=== | ===Enclosure:=== | ||
NRC Inspection Report 05000390 | NRC Inspection Report 05000390/2011003 w/Attachment: Supplemental Information | ||
/2011003 | |||
REGION II== | REGION II== | ||
Docket No: 50-390 License No: NPF-90 Report No: 05000390/2011003 Licensee: Tennessee Valley Authority (TVA) | |||
Docket No: 50-390 License No: NPF-90 | Facility: Watts Bar Nuclear Plant, Unit 1 Location: Spring City, TN 37381 Dates: April 1 - June 30, 2011 Inspectors: R. Monk, Senior Resident Inspector K. Miller, Resident Inspector R. Hamilton, Senior Health Physicist, (2RS1, 2RS2, 4OA1, 4OA5, 4OA6) | ||
W. Loo, Senior Health Physicist, (2RS3, 2RS8) | |||
Report No: 05000390/2011003 Licensee: Tennessee Valley Authority (TVA) | |||
Facility: Watts Bar Nuclear Plant, Unit 1 Location: Spring City, TN 37381 | |||
Dates: April 1 - June 30, 2011 | |||
Inspectors: R. Monk, Senior Resident Inspector K. Miller, Resident Inspector R. Hamilton, Senior Health Physicist, (2RS1, 2RS2, 4OA1, 4OA5, 4OA6) W. Loo, Senior Health Physicist, (2RS3, 2RS8) | |||
M. Coursey, Reactor Inspector (1R08) | M. Coursey, Reactor Inspector (1R08) | ||
Approved by: Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects | Approved by: Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure | ||
Enclosure | |||
=SUMMARY OF FINDINGS= | =SUMMARY OF FINDINGS= | ||
IR 05000390/2011-003; 04/01/2011 - 06/30/2011; Watts Bar, Units 1 & 2; Fire Protection and | IR 05000390/2011-003; 04/01/2011 - 06/30/2011; Watts Bar, Units 1 & 2; Fire Protection and | ||
The report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. Four Green findings were identified, each of which involved non-cited violations (NCVs) of NRC requirements. The significance of most findings is identified by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, | Flood Protection Measures The report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. Four Green findings were identified, each of which involved non-cited violations (NCVs) of NRC requirements. The significance of most findings is identified by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, | ||
Significance Determination Process (SDP); the cross-cutting aspect was determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006. | |||
=== | ===NRC-Identified Findings and Self-Revealing Findings=== | ||
===Cornerstone: Mitigating Systems=== | ===Cornerstone: Mitigating Systems=== | ||
: '''Green.''' | : '''Green.''' | ||
The inspectors identified an NCV of the Unit 1 Operating License Condition 2.F for the | The inspectors identified an NCV of the Unit 1 Operating License Condition 2.F for the licensees failure to maintain the operability of Appendix R emergency lighting in accordance with the approved Fire Protection Plan (FPP). Specifically, both lamps for an Appendix R emergency light in the Unit 2B 480 volt transformer room were not aimed in the direction required by design to accomplish the operator manual action to restore outside air ventilation to the room in the event of a fire, as required by the FPP. The licensee implemented compensatory measures and entered this issue into the corrective action program as Problem Evaluation Report (PER) 341645. | ||
The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using Inspection Manual Chapter (IMC) 0609, Appendix F, Attachment 1, and was determined to be of very low safety significance because it was not a major degradation of FSSD capability. The cause of the finding was directly related to the cross-cutting aspect of Effective Supervisory/Management Oversight in the Work Practices component of the area of Human Performance, in that the licensee did not ensure oversight of work activities that adversely affected the operability of Appendix R emergency lighting (H.4 (c)). | The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using Inspection Manual Chapter (IMC)0609, Appendix F, Attachment 1, and was determined to be of very low safety significance because it was not a major degradation of FSSD capability. The cause of the finding was directly related to the cross-cutting aspect of Effective Supervisory/Management Oversight in the Work Practices component of the area of Human Performance, in that the licensee did not ensure oversight of work activities that adversely affected the operability of Appendix R emergency lighting (H.4 (c)). | ||
(Section 1R05) | (Section 1R05) | ||
: '''Green.''' | : '''Green.''' | ||
The inspectors identified an NCV of Technical Specification 5.7.1, Procedures, for the | The inspectors identified an NCV of Technical Specification 5.7.1, | ||
Procedures, for the licensees failure to maintain a plant procedure to ensure that an operator manual action for fire safe shutdown (FSSD) could be feasibly performed under the current physical plant configuration. Specifically, post-fire safe shutdown procedure AOI-30.2 C.36, Revision 3, contained instructions for an operator manual action for FSSD that could not be feasibly performed following implementation of a plant design change. The licensee took immediate corrective action to install a temporary scaffold as a compensatory measure. The licensee entered this issue into the corrective action program as PER 356563 The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using IMC 0609, Appendix F, | |||
Attachment 1, and was determined to be of very low safety significance because the procedure step in question was not a time-critical step. The cause of the finding was directly related to the cross-cutting aspect of Work Activity Coordination in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately coordinate work activities, consistent with nuclear safety, to ensure that changes to the physical plant configuration would not adversely affect the feasibility of operator manual actions (H.3 (b)). (Section 1R05) | |||
: '''Green.''' | : '''Green.''' | ||
The inspectors identified an NCV of the Unit 1 Operating License Condition 2.F for the | The inspectors identified an NCV of the Unit 1 Operating License Condition 2.F for the licensees failure to store transient combustible materials in a safety-related/critical area of the auxiliary building in accordance with the approved FPP. | ||
Specifically, approximately 38 gallons of hydrocarbon oil was stored inside the entrance labyrinth of the 1B charging pump room without an approved transient combustible evaluation, as required by the FPP. As a result, this was an unapproved increase in fire loading due to an increase in the volume of the predominant combustible material in the area. The licensee took immediate corrective action to remove the drum of oil from the area. The licensee entered this issue into the corrective action program as PER 371383 and PER 380910. | Specifically, approximately 38 gallons of hydrocarbon oil was stored inside the entrance labyrinth of the 1B charging pump room without an approved transient combustible evaluation, as required by the FPP. As a result, this was an unapproved increase in fire loading due to an increase in the volume of the predominant combustible material in the area. The licensee took immediate corrective action to remove the drum of oil from the area. The licensee entered this issue into the corrective action program as PER 371383 and PER 380910. | ||
The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using IMC 0609, Appendix F, Attachment 1, and was determined to be of very low safety significance because it represents a low degradation of fire prevention and administrative controls. The cause of the finding was directly related to the cross-cutting aspect of Proper Work Planning in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately plan work activities to minimize the risk associated with a large quantity of oil in a safety-related fire zone without compensatory measures (H.3 (a)). | The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using IMC 0609, Appendix F, | ||
Attachment 1, and was determined to be of very low safety significance because it represents a low degradation of fire prevention and administrative controls. The cause of the finding was directly related to the cross-cutting aspect of Proper Work Planning in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately plan work activities to minimize the risk associated with a large quantity of oil in a safety-related fire zone without compensatory measures (H.3 (a)). (Section 1R05) | |||
: '''Green.''' | : '''Green.''' | ||
The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control for the | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control for the licensees failure to correctly translate a design document into operating procedures. Specifically, from original Licensing until the beginning of this reporting period, the licensee failed to translate into procedures guidance that would ensure that the plant could be safely shut down following a non-isolable break in the piping connecting the refueling water storage tank (RWST) to the emergency core cooling system in the auxiliary building. The licensee entered this issue into the corrective action program as PER 341568 and corrective actions have been completed to address the issue. | ||
This finding was determined to be more than minor because it adversely affected the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, flood protection was degraded due to a lack of procedures to mitigate flooding from the RWST into the auxiliary building with accompanying damage to both trains of the containment spray motors. This finding was evaluated using the SDP Phase 1 screening criteria in accordance with IMC 0609, Attachment 4, and was determined to require a Phase 3 analysis. The phase 3 analysis was performed by regional | This finding was determined to be more than minor because it adversely affected the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, flood protection was degraded due to a lack of procedures to mitigate flooding from the RWST into the auxiliary building with accompanying damage to both trains of the containment spray motors. This finding was evaluated using the SDP Phase 1 screening criteria in accordance with IMC 0609, Attachment 4, and was determined to require a Phase 3 analysis. The phase 3 analysis was performed by regional SRAs and determined to be of very low safety significance. The cause of the finding extends back to original plant licensing. Therefore, it is not related to current performance and is not assigned a cross-cutting aspect. (See Section 1R06). | ||
=== | ===Licensee-Identified Violations=== | ||
One violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the | One violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the corrective actions are listed in Section 4OA7 of this report. | ||
=REPORT DETAILS= | =REPORT DETAILS= | ||
Line 92: | Line 93: | ||
==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
Cornerstones: | Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity | ||
{{a|1R01}} | |||
{{a|1R01}} | |||
==1R01 Adverse Weather Protection== | ==1R01 Adverse Weather Protection== | ||
Line 100: | Line 100: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Inspectors verified plant features, interviewed control room personnel, and reviewed procedures for operation and continued availability of offsite and alternate AC power systems and determined they were appropriate. Inspectors reviewed the | Inspectors verified plant features, interviewed control room personnel, and reviewed procedures for operation and continued availability of offsite and alternate AC power systems and determined they were appropriate. Inspectors reviewed the licensees procedures and interface agreements affecting these areas and the communications protocol between the northeast area dispatcher and the control room to verify that the appropriate information is exchanged when issues arise that could impact the offsite power system and the alternate AC power system. Also, the inspectors inspected the 161kV offsite switchyard for material condition and reviewed outstanding work orders (WOs) associated with the offsite power distribution system. Documents reviewed are listed in the Attachment. This activity constituted one inspection sample. | ||
====b. Findings==== | ====b. Findings==== | ||
Line 108: | Line 108: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees preparation for and response to an actual tornado warning on April 27. Additionally, the inspectors walked down the safety-related portions of the switchyard. This activity constituted one inspection sample. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R04}} | ||
{{a|1R04}} | |||
==1R04 Equipment Alignment== | ==1R04 Equipment Alignment== | ||
Line 136: | Line 135: | ||
: (6) ancillary equipment or debris did not interfere with system performance; | : (6) ancillary equipment or debris did not interfere with system performance; | ||
: (7) tagging clearances were appropriate; and | : (7) tagging clearances were appropriate; and | ||
: (8) valves were locked as required by the licensee | : (8) valves were locked as required by the licensee=s locked valve program. Pending design and equipment issues were reviewed to determine if the identified deficiencies significantly impacted the system=s functions. Items included in this review were the operator workaround list, the temporary modification list, system health reports, and outstanding maintenance work requests/(WOs). In addition, the inspectors reviewed the licensee=s corrective action program (CAP) to ensure that the licensee was identifying equipment alignment problems and to ensure they were properly addressed for resolution. Documents reviewed are listed in the Attachment. | ||
=s locked valve program. Pending design and equipment issues were reviewed to determine if the identified deficiencies significantly impacted the system | |||
=s functions. Items included in this review were the operator workaround list, the temporary modification list, system health reports, and outstanding maintenance work requests/(WOs). In addition, the inspectors reviewed the licensee | |||
=s corrective action program (CAP) to ensure that the licensee was identifying equipment alignment problems and to ensure they were properly addressed for resolution. Documents reviewed are listed in the Attachment. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R05}} | ||
{{a|1R05}} | |||
==1R05 Fire Protection== | ==1R05 Fire Protection== | ||
Line 149: | Line 144: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors conducted tours of the nine areas important to reactor safety, listed below, to verify the | The inspectors conducted tours of the nine areas important to reactor safety, listed below, to verify the licensees implementation of fire protection requirements as described in the Fire Protection Program, Nuclear Power Group Standard Programs and Processes (NPG-SPP)-18.4.6, Control of Fire Protection Impairments, NPG-SPP-18.4.7, Control of Transient Combustibles, NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work). The inspectors evaluated, as appropriate, conditions related to: | ||
: (1) licensee control of transient combustibles and ignition sources; | : (1) licensee control of transient combustibles and ignition sources; | ||
: (2) the material condition, operational status, and operational lineup of fire protection systems, equipment, and features; and | : (2) the material condition, operational status, and operational lineup of fire protection systems, equipment, and features; and | ||
Line 167: | Line 162: | ||
=====Introduction:===== | =====Introduction:===== | ||
The inspectors identified a Green NCV of the Unit 1 Operating License=== | |||
The inspectors identified a Green NCV of the Unit 1 Operating License Condition 2.F for the | |||
Condition 2.F for the licensees failure to ensure the operability of Appendix R emergency lighting in accordance with the approved Fire Protection Plan (FPP). | |||
Specifically, both lamps for an Appendix R emergency light in the Unit 2B 480 volt transformer room were not aimed in the direction required by design to accomplish the operator manual action to restore outside air ventilation to the room in the event of a fire, as required by the FPP. | |||
=====Description:===== | =====Description:===== | ||
On April 13, 2011, with the plant in Mode 6 Refueling, the inspectors observed in the Unit 2B 480 volt transformer room that both lamps for Appendix R emergency light 2-BAT-228-2419/15 were not aimed in the direction required to illuminate the access and egress route and illuminate the work area to perform the operator manual action to restore ventilation air to the room in the event of a fire. Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, specified the required operator manual action. Procedure 0-FOR-228-3B, Quarterly Inspection and Testing of Emergency Light Battery Packs, Auxiliary Building Elevation Above 737 B Train and Common Areas, specified that the two lamps be aimed at air valve 2-ISV-32-3434 on the ceiling and the general area (acceptance criteria). The lamp mounted on the battery pack was observed aiming at the floor rather than the walkway in the general area and the mount for the remote lamp was observed broken. This remote lamp was hanging by its wires rather than aiming at the instrument air valve (2-ISV-32-3434) near the ceiling. This valve required an operator manual action in the event of a fire to re-position the valve closed to open an associated room ventilation damper. Outside fresh air cooling is necessary for operation of the air-cooled 480 volt transformers contained in the room. | On April 13, 2011, with the plant in Mode 6 Refueling, the inspectors observed in the Unit 2B 480 volt transformer room that both lamps for Appendix R emergency light 2-BAT-228-2419/15 were not aimed in the direction required to illuminate the access and egress route and illuminate the work area to perform the operator manual action to restore ventilation air to the room in the event of a fire. | ||
Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, specified the required operator manual action. Procedure 0-FOR-228-3B, Quarterly Inspection and Testing of Emergency Light Battery Packs, Auxiliary Building Elevation Above 737 B Train and Common Areas, specified that the two lamps be aimed at air valve 2-ISV-32-3434 on the ceiling and the general area (acceptance criteria). The lamp mounted on the battery pack was observed aiming at the floor rather than the walkway in the general area and the mount for the remote lamp was observed broken. This remote lamp was hanging by its wires rather than aiming at the instrument air valve (2-ISV-32-3434) near the ceiling. | |||
This valve required an operator manual action in the event of a fire to re-position the valve closed to open an associated room ventilation damper. Outside fresh air cooling is necessary for operation of the air-cooled 480 volt transformers contained in the room. | |||
Per Part II of the approved Fire Protection Report (FPR), the FPP, Section 14.9, Emergency Battery Lighting Units, the emergency battery lighting units provided for fire safe shutdown (FSSD) shall be operable whenever the illuminated associated fire safe shutdown equipment is required. The inspectors notified TVA Fire Operations of the observation and verified that no previous compensatory measures were in place for the condition. TVA Fire Operations took immediate action to establish compensatory actions and initiate corrective action to comply with the FPP. | Per Part II of the approved Fire Protection Report (FPR), the FPP, Section 14.9, Emergency Battery Lighting Units, the emergency battery lighting units provided for fire safe shutdown (FSSD) shall be operable whenever the illuminated associated fire safe shutdown equipment is required. The inspectors notified TVA Fire Operations of the observation and verified that no previous compensatory measures were in place for the condition. TVA Fire Operations took immediate action to establish compensatory actions and initiate corrective action to comply with the FPP. | ||
=====Analysis:===== | =====Analysis:===== | ||
The inspectors determined that the | The inspectors determined that the licensees failure to ensure the operability of emergency lighting in accordance with the approved FPP, Section 14.9, Emergency Battery Lighting Units, is a performance deficiency. The performance deficiency was determined to be more than minor because it affected the protection against external events attribute (i.e., fire) of the Mitigating Systems cornerstone, in that it affects the objective of ensuring availability, reliability, and capability of systems that respond to initiating events. Because the finding adversely affected, to some degree, the ability to carry out local operator actions required to achieve and maintain a FSSD condition following a severe fire, the inspectors completed a significance determination process (SDP) Phase 1 analysis that indicated the finding was not a major degradation of FSSD capability and, therefore, was of very low significance. The conclusion of degradation significance was based on the procedure step in question not being a time-critical step. | ||
Consideration was also given to the requirement that operators carry flashlights and would have access to portable lanterns to provide the necessary lighting. The cause of the finding was directly related to the cross-cutting aspect of Effective Supervisory/Management Oversight in the Work Practices component of the area of Human Performance, in that the licensee did not ensure oversight of work activities that adversely affected the operability of Appendix R emergency lighting (H.4 (c)). | |||
=====Enforcement:===== | =====Enforcement:===== | ||
Line 183: | Line 187: | ||
Contrary to the above, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). Specifically, the licensee failed to implement the requirements of the FPP, Section 14.9, Emergency Battery Lighting Units, by failing to ensure that work activities did not adversely affect the operability of Appendix R emergency lighting from February 3, 2011, to April 13, 2011. On April 13, 2011, the licensee took immediate action to establish compensatory actions and initiate corrective action to comply with the FPP. | Contrary to the above, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). Specifically, the licensee failed to implement the requirements of the FPP, Section 14.9, Emergency Battery Lighting Units, by failing to ensure that work activities did not adversely affect the operability of Appendix R emergency lighting from February 3, 2011, to April 13, 2011. On April 13, 2011, the licensee took immediate action to establish compensatory actions and initiate corrective action to comply with the FPP. | ||
Because this finding was of low safety significance (Green) and was entered into the | Because this finding was of low safety significance (Green) and was entered into the licensees corrective action program as problem evaluation report (PER) 354437 with corrective actions documented in PER 341645. This violation is being treated as a non-cited violation (NCV), consistent with the NRC Enforcement Policy and is identified as NCV 05000390/2011003-01, Failure to Ensure the Operability of an Emergency Battery Lighting Unit in Accordance with the Approved Fire Protection Plan. | ||
===.2 | ===.2 | ||
=====Introduction:===== | =====Introduction:===== | ||
The inspectors identified a Green NCV of Technical Specification 5.7.1,=== | |||
The inspectors identified a Green NCV of Technical Specification 5.7.1, Procedures, for the | |||
Procedures, for the licensees failure to maintain post-fire safe shutdown procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, following a plant modification. | |||
Specifically, an operator manual action for FSSD contained in AOI-30.2 C.36 could not be feasibly performed due to a change in physical plant configuration. | Specifically, an operator manual action for FSSD contained in AOI-30.2 C.36 could not be feasibly performed due to a change in physical plant configuration. | ||
=====Description:===== | =====Description:===== | ||
On April 13, 2011, with the plant in Mode 6 Refueling, the inspectors identified that in the Unit 2B 480 volt transformer room (Room 772.0-A11), the installation of new electrical conduits prevented the use of an | On April 13, 2011, with the plant in Mode 6 Refueling, the inspectors identified that in the Unit 2B 480 volt transformer room (Room 772.0-A11), the installation of new electrical conduits prevented the use of an emergency operating procedure use only eight-foot step ladder necessary to perform an operator manual action. The conduit was installed per design change notice (DCN) 53334-A in support of Unit 2 construction activities. The action required an operator to access a valve near the ceiling to perform an operator manual action in the event of a fire in Analysis Volume 36 (i.e., Room 737-A1A). Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, was an implementing procedure for the facility fire protection program as described in the FPR which specified the manual actions which may be required for fires potentially affecting safety equipment necessary to achieve and maintain post-fire safe shutdown. | ||
Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Attachment 4, Local Area Operator (AUO) #4 Actions, specifies the required operator manual action to open room ventilation damper 2-FCO-30-246A. Outside fresh air cooling is necessary for operation of the air-cooled 480 volt transformers contained in the room. The operator manual action requires closing an instrument air valve (2-ISV-32-3434) near the ceiling in the event of a fire to fail open the associated damper. The inspectors notified TVA Fire Operations of the observation and verified that no previous compensatory measures were in place for the condition. TVA Fire Operations took immediate action to establish compensatory measures, including the erection of temporary scaffolding providing operator access to the instrument air valve. TVA Fire Operations also took immediate action to initiate corrective action to comply with Part II of the FPR, the FPP, Section 14.10, Fire Safe Shutdown Equipment. | |||
=====Analysis:===== | =====Analysis:===== | ||
The inspectors determined that the | The inspectors determined that the licensees failure to ensure that an operator manual action for FSSD could be feasibly performed under the current physical plant configuration was a performance deficiency. The performance deficiency was determined to be more than minor because it affected the protection against external events attribute (i.e., fire) of the Mitigating Systems cornerstone, in that it affected the objective of ensuring availability, reliability, and capability of systems that respond to initiating events. A fire in the plant locations associated with Analysis Volume 36 could potentially affect systems and components necessary to maintain the steam generator inventory control; long term decay heat removal; fire pumps; reactor coolant inventory control; reactor pressure control; containment heating, ventilation, and air conditioning; secondary side isolation; and containment integrity functions. Mitigating features are required to restore systems necessary for safe shutdown. Specifically, safe shutdown is achieved through the use of the B-train residual heat removal (RHR) and charging pumps, the TDAFW pump, and associated flow paths. The required mitigating features in the event of a fire in Analysis Volume 36 include manual operation of equipment required for safe shutdown. This includes restoration of room cooling to the Unit 2B 480 volt transformer room per Procedure AOI-30.2 C.36. Because the finding adversely affected, to some degree, the ability to carry out local operator actions required to achieve and maintain a FSSD condition following a severe fire, the inspectors completed a SDP Phase 1 analysis that indicated the finding was not a major degradation of FSSD capability and, therefore, was of very low significance. The conclusion of degradation significance was based on the procedure step in question was not a time-critical step. | ||
The cause of the finding was directly related to the cross-cutting aspect of Work Activity Coordination in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately coordinate work activities, consistent with nuclear safety, to ensure that changes to the physical plant configuration would not adversely affect the feasibility of operator manual actions (H.3 (b)). | |||
=====Enforcement:===== | =====Enforcement:===== | ||
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Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, was an implementing procedure for the facility fire protection program. | Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, was an implementing procedure for the facility fire protection program. | ||
Contrary to the above, from July 14, 2009 to April 13, 2011, the licensee failed to adequately maintain AOI-30.2 C.36 following implementation of a plant design change. Specifically, a manual action contained in AOI-30.2 C.36 could not be feasibly performed due to a change in physical plant configuration which prevented the use of the required eight-foot step ladder to access a system valve. The licensee took immediate corrective action on April 13, 2011, to establish compensatory actions as a result of the conduit installation and initiate corrective action to comply with the FPP. Because this finding was of low safety significance (Green) and was entered into the | Contrary to the above, from July 14, 2009 to April 13, 2011, the licensee failed to adequately maintain AOI-30.2 C.36 following implementation of a plant design change. | ||
Specifically, a manual action contained in AOI-30.2 C.36 could not be feasibly performed due to a change in physical plant configuration which prevented the use of the required eight-foot step ladder to access a system valve. The licensee took immediate corrective action on April 13, 2011, to establish compensatory actions as a result of the conduit installation and initiate corrective action to comply with the FPP. Because this finding was of low safety significance (Green) and was entered into the licensees corrective action program as PER 356563, this violation is being treated as an NCV consistent with the NRC Enforcement Policy and is identified as NCV 05000390/2011003-02, Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Non-feasible Operator Manual Action. | |||
===.3 | ===.3 | ||
=====Introduction:===== | =====Introduction:===== | ||
The inspectors identified a Green NCV of the Unit 1 Operating License=== | |||
The inspectors identified a Green NCV of the Unit 1 Operating License Condition 2.F for the | |||
Condition 2.F for the licensees failure to store transient combustible materials in a safety-related/critical area of the auxiliary building in accordance with the approved FPP. | |||
Specifically, approximately 38 gallons of hydrocarbon oil was stored inside the entrance labyrinth of the 1B charging pump room without an approved transient combustible evaluation, as required by the FPP. | Specifically, approximately 38 gallons of hydrocarbon oil was stored inside the entrance labyrinth of the 1B charging pump room without an approved transient combustible evaluation, as required by the FPP. | ||
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=====Analysis:===== | =====Analysis:===== | ||
The inspectors determined that the | The inspectors determined that the licensees failure to perform a transient combustible evaluation for the storage of a large quantity of oil in a safety-related charging pump room in accordance with the approved FPP, Section 10.0, Control of Combustibles, was a performance deficiency. The performance deficiency was determined to be more than minor because it affected the protection against external events attribute (i.e., fire) of the Mitigating Systems cornerstone, in that, it affected the objective of ensuring availability, reliability, and capability of systems that respond to initiating events. Because the finding increased the fire loading due to an increase in the volume of the predominant combustible material in the area by approximately 72 percent; the inspectors completed a SDP Phase 1 and Phase 2 analysis that indicated the finding was not a major degradation of fire prevention and administrative controls. | ||
The cause of the finding was directly related to the cross-cutting aspect of Proper Work Planning in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately plan work activities to minimize the risk associated with a large quantity of oil in a safety-related fire zone without compensatory measures. (H.3 (a)). | |||
=====Enforcement:===== | =====Enforcement:===== | ||
Watts Bar Unit 1 Operating License Condition 2.F requires that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). The FPP, Section 10.0, Control of Combustibles, requires that the use and handling of flammable/combustible gases and liquids are controlled in safety-related areas. Implementing procedure NPG-SPP-18.4.7, Control of Transient Combustibles, Section 3.2.1.J., specifies that flammable and combustible liquids shall be stored in approved storage rooms or storage cabinets when not in use. | Watts Bar Unit 1 Operating License Condition 2.F requires that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). The FPP, Section 10.0, Control of Combustibles, requires that the use and handling of flammable/combustible gases and liquids are controlled in safety-related areas. Implementing procedure NPG-SPP-18.4.7, Control of Transient Combustibles, Section 3.2.1.J., specifies that flammable and combustible liquids shall be stored in approved storage rooms or storage cabinets when not in use. | ||
Contrary to the above, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). Specifically, the licensee failed to implement the requirements of the FPP, Section 10.0, Control of Combustibles, by failing to perform a transient combustible evaluation for the storage of a large quantity of oil in a safety-related charging pump room from April 21, 2011, to March 18, 2011. On March 18, 2011, the licensee took immediate action to remove the transient drum of oil from the 1B charging pump room to comply with the FPP. Because this finding was of low safety significance (Green) and was entered into the | Contrary to the above, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). Specifically, the licensee failed to implement the requirements of the FPP, Section 10.0, Control of Combustibles, by failing to perform a transient combustible evaluation for the storage of a large quantity of oil in a safety-related charging pump room from April 21, 2011, to March 18, 2011. On March 18, 2011, the licensee took immediate action to remove the transient drum of oil from the 1B charging pump room to comply with the FPP. Because this finding was of low safety significance (Green) and was entered into the licensees corrective action program as PER 371383 and PER 380910, this violation is being treated as an NCV consistent with the NRC Enforcement Policy and is identified as NCV 05000390/2011003-03, Failure to Perform a Transient Combustible Evaluation for Storage of Oil in a Safety Related Area in Accordance with the Approved Fire Protection Plan. | ||
{{a|1R06}} | {{a|1R06}} | ||
==1R06 Flood Protection Measures== | ==1R06 Flood Protection Measures== | ||
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=====Description.===== | =====Description.===== | ||
During a baseline inspection of the | During a baseline inspection of the licensees flooding mitigation equipment and procedures, the inspectors determined that a portion of the design output of WBNOSG4099, Moderate Energy Line Break Flooding Study was not translated into plant procedures. Specifically, Appendix I, table I3 states that in the event of a non-isolable leak in the RWST piping connecting to the ECCS system, that a pump of 306 gpm capacity would be installed within 10.6 hours. No procedure existed that would implement this requirement. | ||
=====Analysis:===== | =====Analysis:===== | ||
The inspectors determined that the failure to have a procedure for an internal flooding event in the Auxiliary Building was a performance deficiency. This performance deficiency was determined to be greater than minor because if it had been left uncorrected it would have the potential to lead to a more significant safety concern i.e., longer risk exposure to an unmitigated internal flooding event. The inspectors evaluated the finding using the SDP in accordance with IMC 0609, | The inspectors determined that the failure to have a procedure for an internal flooding event in the Auxiliary Building was a performance deficiency. This performance deficiency was determined to be greater than minor because if it had been left uncorrected it would have the potential to lead to a more significant safety concern i.e., | ||
longer risk exposure to an unmitigated internal flooding event. The inspectors evaluated the finding using the SDP in accordance with IMC 0609, Significance Determination Process, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. The inspectors determined the finding was potentially greater than very low safety significance because as described in the Mitigation System Cornerstone, the finding screened as potentially risk significant due to a seismic, flooding or severe weather initiating event. Consequently a Phase 3 analysis was required. The analysts determined the lack of internal flooding mitigation due to a RWST pipe rupture was of very low risk significance i.e., Green. The main contributors to the low risk results were: | |||
1) the low likelihood of a spontaneous pipe rupture in a low/medium pressure system, and 2) the limited risk consequences of damaging the components affected by the postulated flood i.e., the containment spray pumps and the RHR pump room coolers. | |||
Further, the analysts determined that the precursor event (a piping rupture) would not cause an initiating event (e.g., loss of offsite power, main steam line break). | |||
Consequently the analyst assumed that the worst case scenario would be a forced reactor shutdown due to the loss of inventory from the RWST. The cause of the finding extends back to original plant licensing. Therefore, it is not related to current performance and is not assigned a cross-cutting aspect. | |||
=====Enforcement.===== | =====Enforcement.===== | ||
Title 10 CFR Part 50, Appendix B, Criterion III requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee failed to translate a portion of design document WBNOSG4099, Moderate Energy Lie Break Flooding Study into a procedure that would mitigate certain instances of internal plant flooding. The safety significance of this inspection finding has been characterized by the Significance Determination Process phase 3 and determined to be Green or of very low risk significance. Because this finding was of low safety significance (Green) and has been entered in the | Title 10 CFR Part 50, Appendix B, Criterion III requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee failed to translate a portion of design document WBNOSG4099, Moderate Energy Lie Break Flooding Study into a procedure that would mitigate certain instances of internal plant flooding. The safety significance of this inspection finding has been characterized by the Significance Determination Process phase 3 and determined to be Green or of very low risk significance. Because this finding was of low safety significance (Green) and has been entered in the licensees corrective action program as PER 341568, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy: NCV 05000390/2011003-04, Failure to Translate Moderate Energy Line Break Study Output into a Plant Procedure. | ||
{{a|1R08}} | {{a|1R08}} | ||
==1R08 Inservice Inspection (ISI) Activities (IP 71111.08P, Unit 1)== | ==1R08 Inservice Inspection (ISI) Activities (IP 71111.08P, Unit 1)== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
From April 11-15, 2011, the inspectors reviewed the implementation of the | From April 11-15, 2011, the inspectors reviewed the implementation of the licensees Risk Informed In-service Inspection (ISI) program for monitoring degradation of the reactor coolant system (RCS) boundary and risk significant piping boundaries. The inspectors activities consisted of an on-site review of Non-Destructive Evaluation (NDE)and welding activities to evaluate compliance with the applicable edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC), | ||
Section XI (Code of record: 2000 Edition through the 2001 Addenda), and that indications and defects (if present) were appropriately evaluated and dispositioned in accordance with the requirements of the ASME Code, Section XI acceptance standards. | Section XI (Code of record: 2000 Edition through the 2001 Addenda), and that indications and defects (if present) were appropriately evaluated and dispositioned in accordance with the requirements of the ASME Code, Section XI acceptance standards. | ||
The inspectors review of NDE activities specifically covered examination procedures, NDE reports, equipment and consumables certification records, personnel qualification records, and calibration reports (as applicable) for the following examinations: | The inspectors review of NDE activities specifically covered examination procedures, NDE reports, equipment and consumables certification records, personnel qualification records, and calibration reports (as applicable) for the following examinations: | ||
* Ultrasonic Testing (UT) examination of weld SIS-325 Elbow to Pipe weld | * Ultrasonic Testing (UT) examination of weld SIS-325 Elbow to Pipe weld | ||
* Visual Testing (VT) examination of 555-18-18-2 Containment Spray support The inspectors | * Visual Testing (VT) examination of 555-18-18-2 Containment Spray support The inspectors review of welding activities specifically covered the welding activity listed below in order to evaluate compliance with procedures and the ASME Code. The inspectors reviewed the work order, repair and replacement plan, weld data sheets, welding procedures, procedure qualification records, welder qualification records, and NDE reports. | ||
* Replace valve 1-RFV-070-521 for welds 1-070A-T019-15 and 1-070A-T019-16 | * Replace valve 1-RFV-070-521 for welds 1-070A-T019-15 and 1-070A-T019-16 | ||
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Specifically, the inspectors reviewed the following documentation: | Specifically, the inspectors reviewed the following documentation: | ||
* Evaluated if the required visual examination scope/coverage was achieved and limitations (if applicable) were recorded in accordance with the licensee procedures. | * Evaluated if the required visual examination scope/coverage was achieved and limitations (if applicable) were recorded in accordance with the licensee procedures. | ||
* Evaluated if the | * Evaluated if the licensees criteria for visual examination quality and instructions for resolving interference and masking issues were adequate. | ||
The licensee did not perform any weld repairs to vessel head penetrations since the beginning of the last Unit 1 outage. Therefore, no NRC review was completed for this inspection procedure attribute. | The licensee did not perform any weld repairs to vessel head penetrations since the beginning of the last Unit 1 outage. Therefore, no NRC review was completed for this inspection procedure attribute. | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees BACC program activities to ensure implementation with commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary, and applicable industry guidance documents. Specifically, the inspectors performed an on-site record review of procedures and the results of the licensees containment walk-down inspections performed during the Unit 1 Spring 2011 outage. The inspectors also interviewed the BACC program owner and conducted an independent walk-down of the reactor building to evaluate compliance with licensees BACC program requirements and verify that degraded or non-conforming conditions, such as boric acid leaks identified during the containment walk-down, were properly identified and corrected in accordance with the licensees BACC and Corrective Action Programs. | ||
The inspectors also evaluated the corrective actions for any degraded reactor coolant system components against ASME Code Section XI and other licensee committed documents: | The inspectors also evaluated the corrective actions for any degraded reactor coolant system components against ASME Code Section XI and other licensee committed documents: | ||
* WO 110770187 | * WO 110770187 1-PDIS-62-97 Differential pressure gauge | ||
* WO 111067817 1-ISIV-63-386C Panel 1-L-136 leak The inspectors reviewed a sample of engineering evaluations completed for evidence of boric acid found on systems containing borated water to verify that the minimum design code required section thickness had been maintained for the affected components. The inspectors selected the following evaluations for review: | * WO 111067817 1-ISIV-63-386C Panel 1-L-136 leak The inspectors reviewed a sample of engineering evaluations completed for evidence of boric acid found on systems containing borated water to verify that the minimum design code required section thickness had been maintained for the affected components. The inspectors selected the following evaluations for review: | ||
* PER 217371 | * PER 217371 CVCS Seal Water Injection Filter A differential pressure meter | ||
* PER 234520 Panel 1-6-136 at test tee connection | * PER 234520 Panel 1-6-136 at test tee connection | ||
* PER 307990 WBN 1-PDIS-062-0097 wet boron around high pressure side of fitting | * PER 307990 WBN 1-PDIS-062-0097 wet boron around high pressure side of fitting | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
No SG eddy current testing (ECT) or secondary side visual exams were scheduled for this outage. The inspectors reviewed the | No SG eddy current testing (ECT) or secondary side visual exams were scheduled for this outage. The inspectors reviewed the licensees steam generator degradation assessment for compliance with the EPRI Pressurized Water Reactor Steam Generator Examination Guidelines, Rev.7. | ||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed a review of ISI-related problems, including welding, BACC, and SGISI and that were identified by the licensee and entered into the corrective action program as Condition Reports (CRs). The inspectors reviewed the CRs to confirm that the licensee had appropriately described the scope of the problem and had initiated corrective actions. The review also included the | The inspectors performed a review of ISI-related problems, including welding, BACC, and SGISI and that were identified by the licensee and entered into the corrective action program as Condition Reports (CRs). The inspectors reviewed the CRs to confirm that the licensee had appropriately described the scope of the problem and had initiated corrective actions. The review also included the licensees consideration and assessment of operating experience events applicable to the plant. The inspectors performed this review to ensure compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified | No findings were identified | ||
{{a|1R11}} | |||
{{a|1R11}} | |||
==1R11 Licensed Operator Requalification== | ==1R11 Licensed Operator Requalification== | ||
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The inspectors also attended the critique to assess the effectiveness of the licensee evaluators and to verify that licensee-identified issues were comparable to issues identified by the inspector. | The inspectors also attended the critique to assess the effectiveness of the licensee evaluators and to verify that licensee-identified issues were comparable to issues identified by the inspector. | ||
The inspectors specifically evaluated the following attributes related to the operating crews | The inspectors specifically evaluated the following attributes related to the operating crews performance: | ||
* Clarity and formality of communication | * Clarity and formality of communication | ||
* Ability to take timely action to safely control the unit | * Ability to take timely action to safely control the unit | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R12}} | ||
{{a|1R12}} | |||
==1R12 Maintenance Effectiveness== | ==1R12 Maintenance Effectiveness== | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R13}} | ||
{{a|1R13}} | |||
==1R13 Maintenance Risk Assessments and Emergent Work Control== | ==1R13 Maintenance Risk Assessments and Emergent Work Control== | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R15}} | ||
{{a|1R15}} | |||
==1R15 Operability Evaluations== | ==1R15 Operability Evaluations== | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R18}} | ||
{{a|1R18}} | |||
==1R18 Plant Modifications== | ==1R18 Plant Modifications== | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R19}} | ||
{{a|1R19}} | |||
==1R19 Post-Maintenance Testing== | ==1R19 Post-Maintenance Testing== | ||
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* WO 1100790050 on 1-FCV-63-22 and WO 110790024 on 1-FCV-63-157 - DCN 51659, Spring pack replacement (on both valves) | * WO 1100790050 on 1-FCV-63-22 and WO 110790024 on 1-FCV-63-157 - DCN 51659, Spring pack replacement (on both valves) | ||
* WO 10-816046, 1-SI-3-923B, Auxiliary feedwater pump 1B-B comprehensive test; PMT for 1-PCV-3-132 - DCN 57975 | * WO 10-816046, 1-SI-3-923B, Auxiliary feedwater pump 1B-B comprehensive test; PMT for 1-PCV-3-132 - DCN 57975 | ||
* WO 10-815777-000, Replacement of EGR and servo valve for TDAFW pump | * WO 10-815777-000, Replacement of EGR and servo valve for TDAFW pump PMT per 1-SI-3-923-5, Auxiliary feedwater pump 1A-S comprehensive pump test | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified | No findings were identified | ||
{{a|1R20}} | |||
{{a|1R20}} | |||
==1R20 Refueling and Outage Activities== | ==1R20 Refueling and Outage Activities== | ||
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The inspectors reviewed the outage risk control plan for the upcoming Unit 1 Cycle 10 (U1C10) refueling outage (RFO) to assess whether the licensee had appropriately considered risk, industry experience, and previous site-specific problems, and to also confirm that the licensee had mitigation/response strategies for losses of key safety functions. Additional documents reviewed are listed in the Attachment. | The inspectors reviewed the outage risk control plan for the upcoming Unit 1 Cycle 10 (U1C10) refueling outage (RFO) to assess whether the licensee had appropriately considered risk, industry experience, and previous site-specific problems, and to also confirm that the licensee had mitigation/response strategies for losses of key safety functions. Additional documents reviewed are listed in the Attachment. | ||
The licensee began its U1C10 RFO on April 4, 2011. From that date through the end of the RFO, the inspectors observed portions of the shutdown, cool down, defueling, maintenance activities, refueling, heatup, and startup to verify that the licensee maintained defense-in-depth (DID) commensurate with the outage risk plan and applicable TS. During the outage, the inspectors also reviewed the | The licensee began its U1C10 RFO on April 4, 2011. From that date through the end of the RFO, the inspectors observed portions of the shutdown, cool down, defueling, maintenance activities, refueling, heatup, and startup to verify that the licensee maintained defense-in-depth (DID) commensurate with the outage risk plan and applicable TS. During the outage, the inspectors also reviewed the licensees control of heavy loads to ensure the licensee was properly handling heavy loads in areas where a load drop could impact fuel in the reactor core or equipment that would be required to achieve safe shutdown. Inspectors observed the initial head lift to verify that it complied with the safe load path specified in licensee procedures. | ||
The inspectors monitored licensee controls over the outage activities listed below. In addition, the inspectors reviewed the | The inspectors monitored licensee controls over the outage activities listed below. In addition, the inspectors reviewed the licensees CAP to ensure that the licensee was identifying equipment alignment problems and that they were properly addressed for resolution. | ||
* Licensee configuration management, including daily outage reports, to evaluate Defense in Depth (DID) commensurate with the outage safety plan and compliance with the applicable TS when taking equipment out of service | * Licensee configuration management, including daily outage reports, to evaluate Defense in Depth (DID) commensurate with the outage safety plan and compliance with the applicable TS when taking equipment out of service | ||
* Installation and configuration of reactor coolant instruments to provide accurate indication and an accounting for instrument error | * Installation and configuration of reactor coolant instruments to provide accurate indication and an accounting for instrument error | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified | No findings were identified | ||
{{a|1R22}} | |||
{{a|1R22}} | |||
==1R22 Surveillance Testing== | ==1R22 Surveillance Testing== | ||
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The inspectors witnessed eight surveillance tests and/or reviewed test data of selected risk-significant SSCs, listed below, to assess, as appropriate, whether the SSCs met the requirements of the TS; the UFSAR; SPP-8.0, Testing Programs; NPG-SPP-06.9.2, Surveillance Test Program; and SPP-9.1, ASME Section XI. The inspectors also determined whether the testing effectively demonstrated that the SSCs were operationally ready and capable of performing their intended safety functions. | The inspectors witnessed eight surveillance tests and/or reviewed test data of selected risk-significant SSCs, listed below, to assess, as appropriate, whether the SSCs met the requirements of the TS; the UFSAR; SPP-8.0, Testing Programs; NPG-SPP-06.9.2, Surveillance Test Program; and SPP-9.1, ASME Section XI. The inspectors also determined whether the testing effectively demonstrated that the SSCs were operationally ready and capable of performing their intended safety functions. | ||
In-Service Test | In-Service Test: | ||
: | |||
* WO 112106660, 0-SI-67-922-B, WBN-0-PMP-067-0051-B, Emergency Raw Cooling Water F-B Preservice Test | * WO 112106660, 0-SI-67-922-B, WBN-0-PMP-067-0051-B, Emergency Raw Cooling Water F-B Preservice Test | ||
* WO 10-815958-000, 1-SI-63-906, Safety Injection Check Valve Full-Flow Testing During Refueling Outages | * WO 10-815958-000, 1-SI-63-906, Safety Injection Check Valve Full-Flow Testing During Refueling Outages | ||
* WO 112210948, 1-SI-63-907, Residual Heat Removal Hot Leg and Cold Leg Injection Check Valve Testing During Refueling | * WO 112210948, 1-SI-63-907, Residual Heat Removal Hot Leg and Cold Leg Injection Check Valve Testing During Refueling Containment Isolation Valve (CIV) | ||
Containment Isolation Valve (CIV) | |||
* WO 112013395, 1-SI-67-701A, Containment Isolation Valve Local Leak Rate Test Train-A Upper Compartment ERCW Ice Condenser | * WO 112013395, 1-SI-67-701A, Containment Isolation Valve Local Leak Rate Test Train-A Upper Compartment ERCW Ice Condenser | ||
* WO 10-815970-000, 1-SI-61-4, 40 Months Ice Basket Structural Integrity Visual Inspection Other Surveillances | * WO 10-815970-000, 1-SI-61-4, 40 Months Ice Basket Structural Integrity Visual Inspection Other Surveillances | ||
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No findings were identified. | No findings were identified. | ||
===Cornerstone: | ===Cornerstone: Emergency Preparedness=== | ||
1EP6 Drill Evaluation | 1EP6 Drill Evaluation | ||
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==RADIATION SAFETY== | ==RADIATION SAFETY== | ||
(RS) | (RS) | ||
Cornerstones: | Cornerstones: Occupational Radiation Safety (OS) {{a|2RS1}} | ||
{{a|2RS1}} | |||
==2RS1 Radiological Hazard Assessment and Exposure Control== | ==2RS1 Radiological Hazard Assessment and Exposure Control== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Hazard Assessment and Instructions to workers: | Hazard Assessment and Instructions to workers: During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas and high radiation areas (HRAs) established within the radiologically controlled area (RCA). | ||
The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed and verified survey records for several plant areas including surveys for alpha emitters, airborne radioactivity, and gamma radiation surveys with a range of dose rate gradients. | |||
The inspectors also discussed changes to plant operations with Radiation Protection (RP) supervisors that could contribute to changing radiological conditions since the last inspection. The inspectors attended a pre-job discussion and reviewed several radiation work permits (RWP) to assess communication of radiological control requirements and current radiological conditions to workers. | The inspectors also discussed changes to plant operations with Radiation Protection (RP) supervisors that could contribute to changing radiological conditions since the last inspection. The inspectors attended a pre-job discussion and reviewed several radiation work permits (RWP) to assess communication of radiological control requirements and current radiological conditions to workers. | ||
Hazard Control and Work Practices: | Hazard Control and Work Practices: The inspectors evaluated access barrier effectiveness for selected Locked High Radiation Area (LHRA) and Very High Radiation Area (VHRA) locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with RP supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool were reviewed and discussed. Established radiological controls (including airborne controls) were evaluated for selected tasks including work in auxiliary building HRAs, and radwaste processing and storage. In addition, licensee controls for areas where dose rates could change significantly as a result of plant shutdown and refueling operations were reviewed and discussed. | ||
Occupational workers | Occupational workers adherence to selected RWPs and HP technician (HPT)proficiency in providing job coverage was evaluated through direct observations and interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker stay times were evaluated against area radiation survey results for reviewed RWPs. | ||
Control of Radioactive Material: | Control of Radioactive Material: The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff. | ||
Problem Identification and Resolution: | Problem Identification and Resolution: Summaries of PERS associated with radiological hazard assessment and control were reviewed and assessed for trends and recurrence. | ||
Radiation protection activities were evaluated against the requirements of UFSAR Section 12; TS Sections 5.7 | These summaries contained the full problem description and were broadly categorized as exposure controls, radiation monitoring and surveys, radiological events-radworkers and radiological events-technicians. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure NPG-SPP-3.1, Corrective Action Program, Rev. 1. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. | ||
Radiation protection activities were evaluated against the requirements of UFSAR Section 12; TS Sections 5.7 Procedures, Programs and Manuals and 5.11 High Radiation Areas; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS1 of the Attachment. | |||
The inspectors completed the one specified line-item sample detailed in IP 71124.01. | The inspectors completed the one specified line-item sample detailed in IP 71124.01. | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|2RS2}} | |||
{{a|2RS2}} | |||
==2RS2 As Low As Reasonably Achievable (ALARA)== | ==2RS2 As Low As Reasonably Achievable (ALARA)== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
ALARA Program Status | ALARA Program Status The inspectors reviewed and discussed plant exposure history and current trends including the sites three-year rolling average (TYRA) collective exposure history for calendar year (CY) 2007 through CY 2009. Current and proposed activities to manage site collective exposure and trends regarding collective exposure were evaluated through review of previous TYRA collective exposure data and review of the licensees 5-year ALARA program implementing plan. Current ALARA program guidance and recent changes, as applicable, regarding estimating and tracking exposure were discussed and evaluated. | ||
Radiological Work Planning The inspectors reviewed planned work activities and their collective exposure estimates for Unit 1 Refueling Outage 10 (U1RF10). Work activities, exposure estimates and mitigation activities were reviewed for selected U1RF10 work activities that included thimble tube withdrawal, insertion and replacement and diving in the transfer canal to repair fuel transfer system equipment. For the selected tasks, the inspectors reviewed dose mitigation actions and established dose goals. Current collective dose data for selected tasks were compared with established estimates and, where applicable, changes to established estimates were discussed with responsible licensee ALARA planning representatives. The inspectors observed the preparations for and subsequent execution of a primary filter change out which allowed the inspectors to assess the radiation worker and radiation protection technician work practices. The inspectors reviewed previous post-job reviews conducted for the previous U1RF9 and verified that the items were entered into the licensees CAP for evaluation. | |||
Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed select ALARA work packages and discussed assumptions with responsible planning personal regarding the bases for the current estimates. The licensees dose tracking was reviewed for adequacy with regard to identifying abnormal dose trends and dose distributions. Selected ALARA Packages with work scope additions and/or higher than expected dose rates were selected from the previous outage to review the in-progress and post job review process and the process used to adjust cumulative exposure estimates. | |||
Source Term Reduction and Control The inspectors reviewed historical dose rate trends for shutdown chemistry, cleanup, and resultant chemistry and RP trend-point data against the latest U1RF10 data. The inspectors discussed the benefits of the various source term reduction methods being employed such as ultrasonic fuel cleaning, zinc injection, and macro porous resins. The inspectors also inquired about the initiatives that would be incorporated into Unit 2. | |||
The | Problem Identification and Resolution The inspectors reviewed and discussed selected PERs associated with ALARA program implementation. The reviewed items included PERs, self-assessments, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure NPG-SPP- 03.1, Corrective Action Program, Rev. 1. | ||
The inspectors completed all specified line-items detailed in IP 71124.02 (sample size | The licensees ALARA program activities and results were evaluated against the requirements of UFSAR Section 12; TS Sections 5.7 Procedures, Programs and Manuals and 5.11 High Radiation Areas; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS2 of the report | ||
. | |||
The inspectors completed all specified line-items detailed in IP 71124.02 (sample size of 1). | |||
====b. Findings==== | ====b. Findings==== | ||
: | : | ||
No findings were identified. | |||
{{a|2RS3}} | {{a|2RS3}} | ||
==2RS3 In-Plant Airborne Radioactivity Control and Mitigation== | ==2RS3 In-Plant Airborne Radioactivity Control and Mitigation== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Plant Airborne Radioactivity Controls and Mitigation: | Plant Airborne Radioactivity Controls and Mitigation: The inspectors reviewed the plants Updated Final Safety Analysis Report (UFSAR) to identify areas with the potential for elevated airborne radionuclide concentrations. Selected engineering controls for selected areas of the plant were discussed with radiation protection and operations staff to include the Radwaste Building, Spent Fuel Pool, and the Auxiliary Building. In addition, selected licensee documents including Technical Specifications, UFSAR, design basis documents, Emergency Response Organization rosters, and procedures associated with plant airborne radioactivity controls and monitoring, and with respiratory protection program and emergency planning implementation were reviewed and discussed with cognizant licensee representatives. | ||
Engineering Controls: | Engineering Controls: The inspectors reviewed the use of temporary and permanent engineering controls to mitigate airborne radioactivity for selected work activities. The inspectors observed the use of high efficiency particulate air ventilation and vacuums to control contamination during surface disturbing work. Air sampling analysis results and radiological surveys for selected jobs in contaminated areas with the potential for producing airborne conditions were also reviewed. The inspectors evaluated the effectiveness of continuous air monitors and air samplers placed in selected work area breathing zones to provide indication of increasing airborne levels. | ||
Use of Respiratory Protection Equipment: | Use of Respiratory Protection Equipment: The inspectors reviewed the use of respiratory protection devices to limit the intake of radioactive material. This included review of devices used for routine tasks and devices stored for use in emergency situations. Selected Self-Contained Breathing Apparatus (SCBA) units and negative pressure respirators (NPR) staged for routine and emergency use in the Main Control Room and other locations were inspected for material condition, SCBA bottle air pressure, number of units, and number of spare masks and air bottles available. The inspectors reviewed maintenance records for selected SCBA units and evaluated SCBA and NPR compliance with National Institute for Occupational Safety and Health certification requirements. The inspectors also reviewed records of air quality testing for supplied-air devices and SCBA bottles. | ||
The inspectors reviewed ALARA evaluations for the use of respiratory protection devices for selected work activities conducted during the previous refueling outage. | The inspectors reviewed ALARA evaluations for the use of respiratory protection devices for selected work activities conducted during the previous refueling outage. | ||
Line 538: | Line 544: | ||
In addition, the inspectors walked-down the compressor used for filling SCBA bottles and reviewed records of Grade D air testing for the compressor and instrument air systems. The ability to fill and transport bottles to the control room during an emergency was assessed by the inspectors. | In addition, the inspectors walked-down the compressor used for filling SCBA bottles and reviewed records of Grade D air testing for the compressor and instrument air systems. The ability to fill and transport bottles to the control room during an emergency was assessed by the inspectors. | ||
Self-Contained Breathing Apparatus for Emergency Use: | Self-Contained Breathing Apparatus for Emergency Use: The inspectors reviewed the status and surveillance records of SCBAs staged for in-plant use during emergencies through review of records and walk-down of SCBA staged in the control room, technical support center, and operations support center. The walk-down verified the appropriate number of SCBA kits were staged as specified by the emergency plan, appropriate mask sizes and types available for use, and, through interviews, that users were knowledgeable of storage locations of SCBA, spare masks, and vision correction, as well as how to don and use the equipment. Selected maintenance records for SCBA units and air cylinder hydrostatic testing documentation were reviewed. | ||
Problem Identification and Resolution: | Problem Identification and Resolution: Licensee CAP documents associated with the control and mitigation of in-plant radioactivity were reviewed and assessed. This included review of selected PERs related to use of respiratory protection devices including SCBA. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with procedure NPG-SPP-03.1, Corrective Action Program, Rev. 1. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Licensee CAP documents reviewed are listed in Section 2RS3 of the Attachment. | ||
Radiation protection activities were evaluated against the requirements UFSAR Section 12; 10 CFR Parts 19 and 20; Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection; and approved licensee procedures. Documents reviewed during the inspection are listed in Section | Radiation protection activities were evaluated against the requirements UFSAR Section 12; 10 CFR Parts 19 and 20; Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection; and approved licensee procedures. Documents reviewed during the inspection are listed in Section 2RS3 of the Attachment. | ||
The inspectors completed all specified line-items detailed in IP 71124.03 (sample size of 1). | The inspectors completed all specified line-items detailed in IP 71124.03 (sample size of 1). | ||
Line 552: | Line 554: | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|2RS8}} | |||
==2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and== | |||
Transportation | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Radioactive Waste System Walkdown, Waste Characterization and Classification, and Radioactive Material Storage | Radioactive Waste System Walkdown, Waste Characterization and Classification, and Radioactive Material Storage The inspectors walked down accessible sections of the liquid radwaste system to assess material condition and conformance of equipment with system design diagrams. This included the Radwaste Building containing storage tanks, areas containing abandoned equipment, the Radwaste Control Panel, and the resin processing area. The inspectors discussed the function of radwaste components, as well as the mixing and dewatering of resins with the radwaste contractor. The inspectors discussed possible changes to the radwaste processing systems with the contractor, who indicated that no changes to the systems have been made. The inspectors also observed the physical condition and labeling of several storage containers within the radwaste building. | ||
The inspectors reviewed the 2010 Radioactive Effluent Release Report and the 2010-2011 radionuclide characterization and classification for the Dry Active Waste (DAW) and resin waste streams. The inspectors evaluated analyses for hard-to-detect nuclides, reviewed the use of scaling factors, and examined quality assurance (QA) comparison results between licensee waste stream characterizations and outside laboratory data | The inspectors reviewed the 2010 Radioactive Effluent Release Report and the 2010-2011 radionuclide characterization and classification for the Dry Active Waste (DAW)and resin waste streams. The inspectors evaluated analyses for hard-to-detect nuclides, reviewed the use of scaling factors, and examined quality assurance (QA) comparison results between licensee waste stream characterizations and outside laboratory data. | ||
Shipment Preparation and Records | The inspectors also reviewed how changes to plant operational parameters were taken into account in waste characterization. | ||
Shipment Preparation and Records The inspectors directly observed preparation of the shipment of a High Integrity Container (HIC) containing Low Specific Activity (LSA) bead resin. The inspectors noted package markings and placarding, and interviewed the shipping technician regarding Department of Transportation (DOT) regulations. In addition, training records for selected individuals currently qualified to ship radioactive material were reviewed for compliance with 49 CFR Part 172 Subpart H. | |||
Four licensee shipping records were reviewed for consistency with licensee procedures and compliance with NRC and DOT regulations. This included review of emergency response information, waste classification, radiation survey results, information on the waste manifest, and the authorization of the receiving licensee to receive shipments. | Four licensee shipping records were reviewed for consistency with licensee procedures and compliance with NRC and DOT regulations. This included review of emergency response information, waste classification, radiation survey results, information on the waste manifest, and the authorization of the receiving licensee to receive shipments. | ||
Identification and Resolution of Problems | Identification and Resolution of Problems The inspectors reviewed selected PERs in the area of radwaste/shipping. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with procedure NPG-SPP-03.1, Corrective Action Program, Rev. 1. | ||
The observed storage of radioactive material waste was reviewed for compliance with the labeling and storage requirements of 10 CFR Part 20. Waste stream characterization analyses and how changes to plant parameters were taken into account, were reviewed for compliance with the regulations in 10 CFR Part 61 and guidance provided in the Branch Technical Position on Waste Classification (1983). Transportation program implementation was reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178, as well as the guidance provided in NUREG-1608. Licensee documents reviewed are listed in Section | The observed storage of radioactive material waste was reviewed for compliance with the labeling and storage requirements of 10 CFR Part 20. Waste stream characterization analyses and how changes to plant parameters were taken into account, were reviewed for compliance with the regulations in 10 CFR Part 61 and guidance provided in the Branch Technical Position on Waste Classification (1983). | ||
Transportation program implementation was reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178, as well as the guidance provided in NUREG-1608. Licensee documents reviewed are listed in Section 2RS8 of the | |||
. | |||
====b. Findings==== | ====b. Findings==== | ||
Line 581: | Line 587: | ||
The inspectors sampled licensee submittals for the two PIs listed below. To verify the accuracy of the PI data reported during the periods listed, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Revision 5, were used to verify the basis in reporting for each data element. | The inspectors sampled licensee submittals for the two PIs listed below. To verify the accuracy of the PI data reported during the periods listed, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Revision 5, were used to verify the basis in reporting for each data element. | ||
* RCS Leakage | * RCS Leakage | ||
* Safety System Functional Failures Occupational Radiation Safety Cornerstone: | * Safety System Functional Failures Occupational Radiation Safety Cornerstone: The inspectors reviewed Performance Indicator (PI) data collected from October 1, 2009, through March 30, 2011, for the Occupational Exposure Control Effectiveness PI. For the reviewed period, the inspectors assessed CAP records to determine whether HRA, VHRA, or unplanned exposures, resulting in TS or 10 CFR 20 non-conformances, had occurred during the review period. In addition, the inspectors reviewed selected personnel contamination event data, internal dose assessment results, and ED alarms for cumulative doses and/or dose rates exceeding established set-points. The reviewed data were assessed against guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline," | ||
Rev. 6. The reviewed documents relative to these PI reviews are listed in Sections 2RS1 of the Attachment. | |||
Public Radiation Safety Cornerstone The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from June 2010, through May 2011. For the assessment period, the inspectors reviewed cumulative and projected doses to the public and PER documents related to Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual issues. | |||
The reviewed documents relative to this PI are listed in Section 4OA1 of the Attachment. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|4OA2}} | |||
{{a|4OA2}} | |||
==4OA2 Identification & Resolution of Problems== | ==4OA2 Identification & Resolution of Problems== | ||
===.1 Review of Items Entered into the Corrective Action Program (CAP)=== | ===.1 Review of Items Entered into the Corrective Action Program (CAP)=== | ||
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the | As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by reviewing daily PER summary reports and attending daily PER review meetings. | ||
===.2 Semi-Annual Review to Identify Trends=== | ===.2 Semi-Annual Review to Identify Trends=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
As required by IP 71152, Identification and Resolution of Problems, the inspectors performed a review of the | As required by IP 71152, Identification and Resolution of Problems, the inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on human performance trends, licensee trending efforts, and repetitive equipment and corrective maintenance issues. The inspectors also considered the results of the daily inspector CAP item screening discussed in Section 4OA2.1. The inspectors review nominally considered the six-month period of January 2011 through June 2011, although some examples expanded beyond those dates when the scope of the trend warranted. | ||
b. Observations No findings were identified. However, both the inspectors and the licensee identified an increasing number of instances where transient combustibles were not analyzed, Appendix R lighting was broken or the illumination misdirected, and fire doors with various discrepancies up to and including inoperablitiy. See Sections 1R05 and | b. Observations No findings were identified. However, both the inspectors and the licensee identified an increasing number of instances where transient combustibles were not analyzed, Appendix R lighting was broken or the illumination misdirected, and fire doors with various discrepancies up to and including inoperablitiy. See Sections 1R05 and 4OA7 for additional details. An additional trend was observed that the licensee was increasingly identifying issues below the regulatory threshold in the areas of risk assessment, Operations performance and fire protection. | ||
An additional trend was observed that the licensee was increasingly identifying issues below the regulatory threshold in the areas of risk assessment, Operations performance and fire protection. | |||
===.3 Annual Sample: | ===.3 Annual Sample: Corrective actions associated with PER 8733 Reactor Cavity Leakage=== | ||
Corrective actions associated with PER 8733 Reactor Cavity Leakage | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the plan and implementation of corrective actions for reactor cavity leakage, which were documented in PER 8733. | The inspectors reviewed the plan and implementation of corrective actions for reactor cavity leakage, which were documented in PER 8733. | ||
====b. Findings and Observations==== | ====b. Findings and Observations==== | ||
During containment walkdowns in refueling outage RF10, inspectors noted leakage on the order of 2 to 3 gpm from the reactor cavity tell-tale drain valves which were open and routed to a sump. Follow-up of this issue indicated that this was a previously identified problem. The reactor cavity leakage was documented in PER 8733 on September 19, 2003 with the following description: | During containment walkdowns in refueling outage RF10, inspectors noted leakage on the order of 2 to 3 gpm from the reactor cavity tell-tale drain valves which were open and routed to a sump. Follow-up of this issue indicated that this was a previously identified problem. The reactor cavity leakage was documented in PER 8733 on September 19, 2003 with the following description: During flood up to refuel the cavity liner was noted to have about 2 to 3 GPM leakage. This is a repeat problem from other outages. | ||
Inspectors reviewed the PER and found that it had been closed to work order 03-016131-000 on October 22, 2004. Review of the work order indicated that it has remained open with a status of INPLNG (in planning) with no work credited to it. | |||
However, actions have been taken on other work orders to apply strippable coatings to the reactor cavity walls. | However, actions have been taken on other work orders to apply strippable coatings to the reactor cavity walls. | ||
The original 2003 plan was to coat the lower reactor cavity to a level of six feet with a strippable coating and measure leakage. Based on poor results, the next outage, the coating was raised to the lower eight feet. Eight feet also proved to be inadequate and the licensee decided to go to 10 feet the following outage (the outage previous to this reporting period). Observations were that the leak was down to | The original 2003 plan was to coat the lower reactor cavity to a level of six feet with a strippable coating and measure leakage. Based on poor results, the next outage, the coating was raised to the lower eight feet. Eight feet also proved to be inadequate and the licensee decided to go to 10 feet the following outage (the outage previous to this reporting period). Observations were that the leak was down to pencil size. As noted above, the original leakage observed in 2003 was commensurate with the leakage observed by the inspectors. That is, no improvement in the intervening eight years. | ||
The inspectors were unable to verify the extent of the coating for this most recent outage as the licensee has been unable to produce an owner of the issue that would know the status. The licensee is identifying a new owner for this issue for follow-up. | The inspectors were unable to verify the extent of the coating for this most recent outage as the licensee has been unable to produce an owner of the issue that would know the status. The licensee is identifying a new owner for this issue for follow-up. | ||
Line 639: | Line 641: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours. | During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. | ||
These observations took place during both normal and off-normal plant working hours. | |||
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors | These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities. | ||
====b. Findings==== | ====b. Findings==== | ||
Line 647: | Line 651: | ||
===.2 (Closed) Temporary Instruction (TI) 2515/183, Follow-up to Fukushima Daiichi Nuclear=== | ===.2 (Closed) Temporary Instruction (TI) 2515/183, Follow-up to Fukushima Daiichi Nuclear=== | ||
Station Fuel Damage Event | Station Fuel Damage Event | ||
Line 655: | Line 660: | ||
No findings were identified. | No findings were identified. | ||
===.3 (Closed) NRC TI 2515/184, Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs) | ===.3 (Closed) NRC TI 2515/184, Availability and Readiness Inspection of Severe Accident=== | ||
Management Guidelines (SAMGs) | |||
====a. Scope==== | ====a. Scope==== | ||
On May 27, 2011, the inspectors completed a review of the | On May 27, 2011, the inspectors completed a review of the licensees severe accident management guidelines (SAMGs), implemented as a voluntary industry initiative in the 1990s, to determine | ||
: (1) whether the SAMGs were available and updated, | : (1) whether the SAMGs were available and updated, | ||
: (2) whether the licensee had procedures and processes in place to control and update its SAMGs, | : (2) whether the licensee had procedures and processes in place to control and update its SAMGs, | ||
: (3) the nature and extent of the | : (3) the nature and extent of the licensees training of personnel on the use of SAMGs, and | ||
: (4) licensee | : (4) licensee personnels familiarity with SAMG implementation. | ||
The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichi fuel damage event in Japan. Plant-specific results for Watts Bar Station were provided as an Enclosure to a memorandum to the Chief, Reactor Inspection Branch, Division of Inspection and Regional Support, dated June 02, 2011 (ML111530328). | The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichi fuel damage event in Japan. Plant-specific results for Watts Bar Station were provided as an Enclosure to a memorandum to the Chief, Reactor Inspection Branch, Division of Inspection and Regional Support, dated June 02, 2011 (ML111530328). | ||
Line 669: | Line 676: | ||
No findings were identified. | No findings were identified. | ||
===.4 (Closed) TI 2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207) | ===.4 (Closed) TI 2515/179 Verification of Licensee Responses to NRC Requirement for=== | ||
Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207) | |||
====a. Scope==== | ====a. Scope==== | ||
Line 675: | Line 684: | ||
=====Analysis.===== | =====Analysis.===== | ||
The inspectors reviewed the | The inspectors reviewed the licensees source inventory records and identified the sources that met the criteria for reporting to the NSTS. The inspectors visually identified the sources contained in various calibration systems and verified the presence of the source by direct radiation measurement using a calibrated portable radiation detection survey instrument. The inspectors reviewed the physical condition of the irradiation device. The inspectors reviewed the licensees procedures for source receipt, maintenance, transfer, reporting and disposal. The inspectors reviewed documentation that was used to report the sources to the NSTS. Documents reviewed are listed in sections 2RS1 of the Attachment. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. This completes the Region II inspection requirements. | No findings were identified. This completes the Region II inspection requirements. | ||
{{a|4OA6}} | |||
{{a|4OA6}} | |||
==4OA6 Meetings, including Exit== | ==4OA6 Meetings, including Exit== | ||
Line 698: | Line 704: | ||
Inoperable Fire Door The following violation of very low safety significance (Green) was identified by the licensee and was a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. | Inoperable Fire Door The following violation of very low safety significance (Green) was identified by the licensee and was a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. | ||
Facility Operating License NPF-90 for Watts Bar Nuclear Plant Unit 1, Condition 2.F, requires that TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the FPR. Contrary to the above, on April 18, 2011, the licensee found Fire Door A027 latching mechanism taped in a manner that prevented the door from automatically latching. The tape had apparently been placed there by an unknown individual during the refueling due to the inability to open the door from the auxiliary building side to the pipe chase side. The tape was removed restoring the fire door function and the latch assembly was replaced the next day. This was identified in the | Facility Operating License NPF-90 for Watts Bar Nuclear Plant Unit 1, Condition 2.F, requires that TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the FPR. Contrary to the above, on April 18, 2011, the licensee found Fire Door A027 latching mechanism taped in a manner that prevented the door from automatically latching. The tape had apparently been placed there by an unknown individual during the refueling due to the inability to open the door from the auxiliary building side to the pipe chase side. The tape was removed restoring the fire door function and the latch assembly was replaced the next day. This was identified in the licensees CAP as PER 356803. This finding was of very low safety significance in accordance with IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, because the fire barrier was only moderately degraded and there were no fixed or in-situ fire ignition sources that would subject the degraded fire barrier to direct flame impingement. | ||
=SUPPLEMENTAL INFORMATION= | =SUPPLEMENTAL INFORMATION= | ||
Line 705: | Line 711: | ||
===Licensee personnel=== | ===Licensee personnel=== | ||
: [[contact::G. Boerschig]], Plant Manager | : [[contact::G. Boerschig]], Plant Manager | ||
: [[contact::J. Bushnell]], Licensing Engineer | : [[contact::J. Bushnell]], Licensing Engineer | ||
: [[contact::R. Crews]], Operations Training Manager | : [[contact::R. Crews]], Operations Training Manager | ||
: [[contact::T. Detchemende]], Emergency Preparedness Manager | : [[contact::T. Detchemende]], Emergency Preparedness Manager | ||
: [[contact::K. Dutton]], Engineering Director | : [[contact::K. Dutton]], Engineering Director | ||
: [[contact::D. Grissette]], Site Vice President | : [[contact::D. Grissette]], Site Vice President | ||
: [[contact::W. Hooks]], Radiation Protection Manager | : [[contact::W. Hooks]], Radiation Protection Manager | ||
: [[contact::P. Huffman]], ISI Coordinator | : [[contact::P. Huffman]], ISI Coordinator | ||
: [[contact::D. Hughes]], Training Supervisor | : [[contact::D. Hughes]], Training Supervisor | ||
: [[contact::B. Hunt]], Operations Superintendent | : [[contact::B. Hunt]], Operations Superintendent | ||
: [[contact::D. Hutchinson]], Chemistry Manager | : [[contact::D. Hutchinson]], Chemistry Manager | ||
: [[contact::C. Kato]], BACC Coordinator | : [[contact::C. Kato]], BACC Coordinator | ||
: [[contact::W. Mahan]], Site Welding Engineer | : [[contact::W. Mahan]], Site Welding Engineer | ||
: [[contact::M. McFadden]], Operations Manager | : [[contact::M. McFadden]], Operations Manager | ||
: [[contact::J. Milner]], Technical Support Superintendent, Radiation Protection | : [[contact::J. Milner]], Technical Support Superintendent, Radiation Protection | ||
: [[contact::D. Murphy]], Maintenance Manager | : [[contact::D. Murphy]], Maintenance Manager | ||
: [[contact::M. Pope]], Licensing Engineer | : [[contact::M. Pope]], Licensing Engineer | ||
: [[contact::C. Riedl]], Licensing Manager (Interim) | : [[contact::C. Riedl]], Licensing Manager (Interim) | ||
: [[contact::A. Scales]], Work Control Manager | : [[contact::A. Scales]], Work Control Manager | ||
: [[contact::D. Voeller]], Director, Project Management | : [[contact::D. Voeller]], Director, Project Management | ||
: [[contact::J. Wilcox]], Security Manager | : [[contact::J. Wilcox]], Security Manager | ||
==ITEMS OPENED, CLOSED, AND DISCUSSED== | ==ITEMS OPENED, CLOSED, AND DISCUSSED== | ||
===Opened=== | ===Opened=== | ||
None | |||
None | |||
===Opened and Closed=== | ===Opened and Closed=== | ||
: 05000390/2011003-01 NCV Failure to Ensure The Operability of an Emergency Battery Lighting Unit in Accordance with the Approved Fire Protection Plan (Section 1R05) | : 05000390/2011003-01 NCV Failure to Ensure The Operability of an Emergency Battery Lighting Unit in Accordance with the Approved Fire Protection Plan (Section 1R05) | ||
: 05000390/2011003-02 NCV Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Non-feasible Operator Manual Action (Section 1R05) | : 05000390/2011003-02 NCV Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Non-feasible Operator Manual Action (Section 1R05) | ||
: 05000390/2011003-03 NCV Failure to Perform a Transient Combustible Evaluation for Storage of Oil in a Safety Related Area in Accordance with the Approved Fire Protection Plan (Section 1R05) | |||
: 05000390/2011003-03 NCV Failure to Perform a Transient Combustible Evaluation for Storage of Oil in a Safety Related Area in Accordance with the Approved Fire Protection Plan (Section 1R05) | : 05000390/2011003-04 NCV Failure to Translate Moderate Energy Line Break Study Output into a Plant Procedure 2515/183 TI Followup to Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5) | ||
: 05000390/2011003-04 NCV Failure to Translate Moderate Energy Line Break Study Output into a Plant Procedure 2515/183 TI Followup to Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5) | 2515/184 TI Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs) (Section 4OA5) | ||
2515/184 TI Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs) (Section 4OA5) | |||
===Closed=== | ===Closed=== | ||
TI 2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal | : 05000390/2009002-01 URI Auxiliary Feedwater System Compliance with General Design Criterion 2 (Section 1R15). | ||
Regulations, Part 20.2207 (10 CFR 20.2207) | TI 2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207) | ||
===Discussed=== | ===Discussed=== | ||
None | |||
None | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
}} | }} |
Latest revision as of 04:50, 21 December 2019
ML112170278 | |
Person / Time | |
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Site: | Watts Bar ![]() |
Issue date: | 08/05/2011 |
From: | Eugene Guthrie Reactor Projects Region 2 Branch 6 |
To: | Krich R Tennessee Valley Authority |
References | |
IR-11-003 | |
Download: ML112170278 (49) | |
Text
UNITED STATES ugust 5, 2011
SUBJECT:
WATTS BAR NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000390/2011003
Dear Mr. Krich:
On June 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Watts Bar Nuclear Plant, Unit 1. The enclosed integrated inspection report documents the inspection results which were discussed on July 6, 2011, with Mr. D. Grissette 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.
This report documents four NRC-identified findings of very low safety significance (Green).
These findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Watts Bar facility.
In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Watts Bar Nuclear Plant. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
TVA 2 In 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 or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-390 License No.: NPF-90
Enclosure:
NRC Inspection Report 05000390/2011003 w/Attachment: Supplemental Information
REGION II==
Docket No: 50-390 License No: NPF-90 Report No: 05000390/2011003 Licensee: Tennessee Valley Authority (TVA)
Facility: Watts Bar Nuclear Plant, Unit 1 Location: Spring City, TN 37381 Dates: April 1 - June 30, 2011 Inspectors: R. Monk, Senior Resident Inspector K. Miller, Resident Inspector R. Hamilton, Senior Health Physicist, (2RS1, 2RS2, 4OA1, 4OA5, 4OA6)
W. Loo, Senior Health Physicist, (2RS3, 2RS8)
M. Coursey, Reactor Inspector (1R08)
Approved by: Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000390/2011-003; 04/01/2011 - 06/30/2011; Watts Bar, Units 1 & 2; Fire Protection and
Flood Protection Measures The report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. Four Green findings were identified, each of which involved non-cited violations (NCVs) of NRC requirements. The significance of most findings is identified by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP); the cross-cutting aspect was determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified an NCV of the Unit 1 Operating License Condition 2.F for the licensees failure to maintain the operability of Appendix R emergency lighting in accordance with the approved Fire Protection Plan (FPP). Specifically, both lamps for an Appendix R emergency light in the Unit 2B 480 volt transformer room were not aimed in the direction required by design to accomplish the operator manual action to restore outside air ventilation to the room in the event of a fire, as required by the FPP. The licensee implemented compensatory measures and entered this issue into the corrective action program as Problem Evaluation Report (PER) 341645.
The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using Inspection Manual Chapter (IMC)0609, Appendix F, Attachment 1, and was determined to be of very low safety significance because it was not a major degradation of FSSD capability. The cause of the finding was directly related to the cross-cutting aspect of Effective Supervisory/Management Oversight in the Work Practices component of the area of Human Performance, in that the licensee did not ensure oversight of work activities that adversely affected the operability of Appendix R emergency lighting (H.4 (c)).
(Section 1R05)
- Green.
The inspectors identified an NCV of Technical Specification 5.7.1,
Procedures, for the licensees failure to maintain a plant procedure to ensure that an operator manual action for fire safe shutdown (FSSD) could be feasibly performed under the current physical plant configuration. Specifically, post-fire safe shutdown procedure AOI-30.2 C.36, Revision 3, contained instructions for an operator manual action for FSSD that could not be feasibly performed following implementation of a plant design change. The licensee took immediate corrective action to install a temporary scaffold as a compensatory measure. The licensee entered this issue into the corrective action program as PER 356563 The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using IMC 0609, Appendix F,
Attachment 1, and was determined to be of very low safety significance because the procedure step in question was not a time-critical step. The cause of the finding was directly related to the cross-cutting aspect of Work Activity Coordination in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately coordinate work activities, consistent with nuclear safety, to ensure that changes to the physical plant configuration would not adversely affect the feasibility of operator manual actions (H.3 (b)). (Section 1R05)
- Green.
The inspectors identified an NCV of the Unit 1 Operating License Condition 2.F for the licensees failure to store transient combustible materials in a safety-related/critical area of the auxiliary building in accordance with the approved FPP.
Specifically, approximately 38 gallons of hydrocarbon oil was stored inside the entrance labyrinth of the 1B charging pump room without an approved transient combustible evaluation, as required by the FPP. As a result, this was an unapproved increase in fire loading due to an increase in the volume of the predominant combustible material in the area. The licensee took immediate corrective action to remove the drum of oil from the area. The licensee entered this issue into the corrective action program as PER 371383 and PER 380910.
The finding was determined to be more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone, in that it affects the objective of ensuring reliability and capability of systems that respond to initiating events. This finding was evaluated using IMC 0609, Appendix F,
Attachment 1, and was determined to be of very low safety significance because it represents a low degradation of fire prevention and administrative controls. The cause of the finding was directly related to the cross-cutting aspect of Proper Work Planning in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately plan work activities to minimize the risk associated with a large quantity of oil in a safety-related fire zone without compensatory measures (H.3 (a)). (Section 1R05)
- Green.
The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control for the licensees failure to correctly translate a design document into operating procedures. Specifically, from original Licensing until the beginning of this reporting period, the licensee failed to translate into procedures guidance that would ensure that the plant could be safely shut down following a non-isolable break in the piping connecting the refueling water storage tank (RWST) to the emergency core cooling system in the auxiliary building. The licensee entered this issue into the corrective action program as PER 341568 and corrective actions have been completed to address the issue.
This finding was determined to be more than minor because it adversely affected the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, flood protection was degraded due to a lack of procedures to mitigate flooding from the RWST into the auxiliary building with accompanying damage to both trains of the containment spray motors. This finding was evaluated using the SDP Phase 1 screening criteria in accordance with IMC 0609, Attachment 4, and was determined to require a Phase 3 analysis. The phase 3 analysis was performed by regional SRAs and determined to be of very low safety significance. The cause of the finding extends back to original plant licensing. Therefore, it is not related to current performance and is not assigned a cross-cutting aspect. (See Section 1R06).
Licensee-Identified Violations
One violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the corrective actions are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near 100 percent rated thermal power (RTP) until it was removed from service for a scheduled refueling outage beginning April 4, 2011. The unit was started up and went critical on May 20 and entered Mode 1 operation on May 21. On May 22, the turbine tripped due to a loss of electro-hydraulic control when a fitting on the C low pressure turbine intercept valve line failed. The reactor remained in Mode 1 on steam dumps as reactor power was less than the P9 setpoint of 50 percent power when the turbine trip occurred. The leak was repaired and the turbine synchronized to the grid on May 23 and the unit commenced power ascension. On May 25, the Unit 1 had an automatic runback in power from 83 percent to 79 percent RTP due to C intermediate feedwater heater string isolating. On May 29, the reactor automatically tripped from 100 percent power due to a card failure in a newly installed main generator voltage regulator. The trip was uncomplicated. The cards were replaced, and the unit was returned to full power service on June 2 where it operated at or near 100 percent for the balance of the reporting period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Summer Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
Inspectors verified plant features, interviewed control room personnel, and reviewed procedures for operation and continued availability of offsite and alternate AC power systems and determined they were appropriate. Inspectors reviewed the licensees procedures and interface agreements affecting these areas and the communications protocol between the northeast area dispatcher and the control room to verify that the appropriate information is exchanged when issues arise that could impact the offsite power system and the alternate AC power system. Also, the inspectors inspected the 161kV offsite switchyard for material condition and reviewed outstanding work orders (WOs) associated with the offsite power distribution system. Documents reviewed are listed in the Attachment. This activity constituted one inspection sample.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed the licensees preparation for and response to an actual tornado warning on April 27. Additionally, the inspectors walked down the safety-related portions of the switchyard. This activity constituted one inspection sample.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors conducted two equipment alignment partial walkdowns, listed below, to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service. The inspectors reviewed the functional system descriptions, Updated Final Safety Analysis Report (UFSAR), system operating procedures, and technical specifications (TS) to determine correct system lineups for the current plant conditions. The inspectors performed walkdowns of the systems to verify that critical components were properly aligned and to identify any discrepancies which could affect operability of the redundant train or backup system. Documents reviewed are listed in the Attachment.
- Partial walkdown of 2A emergency diesel generator (EDG) while 1B EDG was out of service (OOS) for routine maintenance.
b. Findings
No findings were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors conducted one detailed walkdown/review of the alignment and condition of the residual heat removal system to verify proper equipment alignment and to identify any discrepancies that could impact the function of the system and increase risk. The inspectors utilized licensee procedures, as well as licensing and design documents, when verifying that the system alignment was correct. During the walkdown, the inspectors also verified, as appropriate, that:
- (1) valves were correctly positioned and did not exhibit leakage that would impact the function(s) of any valve;
- (2) electrical power was available as required;
- (3) major portions of the system and components were correctly labeled, cooled, ventilated, etc.;
- (4) hangers and supports were correctly installed and functional;
- (5) essential support systems were operational;
- (6) ancillary equipment or debris did not interfere with system performance;
- (7) tagging clearances were appropriate; and
- (8) valves were locked as required by the licensee=s locked valve program. Pending design and equipment issues were reviewed to determine if the identified deficiencies significantly impacted the system=s functions. Items included in this review were the operator workaround list, the temporary modification list, system health reports, and outstanding maintenance work requests/(WOs). In addition, the inspectors reviewed the licensee=s corrective action program (CAP) to ensure that the licensee was identifying equipment alignment problems and to ensure they were properly addressed for resolution. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
Fire Protection Tours
a. Inspection Scope
The inspectors conducted tours of the nine areas important to reactor safety, listed below, to verify the licensees implementation of fire protection requirements as described in the Fire Protection Program, Nuclear Power Group Standard Programs and Processes (NPG-SPP)-18.4.6, Control of Fire Protection Impairments, NPG-SPP-18.4.7, Control of Transient Combustibles, NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work). The inspectors evaluated, as appropriate, conditions related to:
- (1) licensee control of transient combustibles and ignition sources;
- (2) the material condition, operational status, and operational lineup of fire protection systems, equipment, and features; and
- (3) the fire barriers used to prevent fire damage or fire propagation. This activity constituted 9 inspection samples.
- A-train residual heat removal (RHR) pump room
- B-train RHR pump room
- A-train containment spray (CS) pump room
- B-train CS pump room
- Turbine-driven auxiliary feedwater (TDAFW) room
- A-train centrifugal charging pump (CCP) room
- B-train CCP room
- A-train safety injection pump (SIP) room
- B-train SIP room
b. Findings
===.1
Introduction:
The inspectors identified a Green NCV of the Unit 1 Operating License===
Condition 2.F for the licensees failure to ensure the operability of Appendix R emergency lighting in accordance with the approved Fire Protection Plan (FPP).
Specifically, both lamps for an Appendix R emergency light in the Unit 2B 480 volt transformer room were not aimed in the direction required by design to accomplish the operator manual action to restore outside air ventilation to the room in the event of a fire, as required by the FPP.
Description:
On April 13, 2011, with the plant in Mode 6 Refueling, the inspectors observed in the Unit 2B 480 volt transformer room that both lamps for Appendix R emergency light 2-BAT-228-2419/15 were not aimed in the direction required to illuminate the access and egress route and illuminate the work area to perform the operator manual action to restore ventilation air to the room in the event of a fire.
Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, specified the required operator manual action. Procedure 0-FOR-228-3B, Quarterly Inspection and Testing of Emergency Light Battery Packs, Auxiliary Building Elevation Above 737 B Train and Common Areas, specified that the two lamps be aimed at air valve 2-ISV-32-3434 on the ceiling and the general area (acceptance criteria). The lamp mounted on the battery pack was observed aiming at the floor rather than the walkway in the general area and the mount for the remote lamp was observed broken. This remote lamp was hanging by its wires rather than aiming at the instrument air valve (2-ISV-32-3434) near the ceiling.
This valve required an operator manual action in the event of a fire to re-position the valve closed to open an associated room ventilation damper. Outside fresh air cooling is necessary for operation of the air-cooled 480 volt transformers contained in the room.
Per Part II of the approved Fire Protection Report (FPR), the FPP, Section 14.9, Emergency Battery Lighting Units, the emergency battery lighting units provided for fire safe shutdown (FSSD) shall be operable whenever the illuminated associated fire safe shutdown equipment is required. The inspectors notified TVA Fire Operations of the observation and verified that no previous compensatory measures were in place for the condition. TVA Fire Operations took immediate action to establish compensatory actions and initiate corrective action to comply with the FPP.
Analysis:
The inspectors determined that the licensees failure to ensure the operability of emergency lighting in accordance with the approved FPP, Section 14.9, Emergency Battery Lighting Units, is a performance deficiency. The performance deficiency was determined to be more than minor because it affected the protection against external events attribute (i.e., fire) of the Mitigating Systems cornerstone, in that it affects the objective of ensuring availability, reliability, and capability of systems that respond to initiating events. Because the finding adversely affected, to some degree, the ability to carry out local operator actions required to achieve and maintain a FSSD condition following a severe fire, the inspectors completed a significance determination process (SDP) Phase 1 analysis that indicated the finding was not a major degradation of FSSD capability and, therefore, was of very low significance. The conclusion of degradation significance was based on the procedure step in question not being a time-critical step.
Consideration was also given to the requirement that operators carry flashlights and would have access to portable lanterns to provide the necessary lighting. The cause of the finding was directly related to the cross-cutting aspect of Effective Supervisory/Management Oversight in the Work Practices component of the area of Human Performance, in that the licensee did not ensure oversight of work activities that adversely affected the operability of Appendix R emergency lighting (H.4 (c)).
Enforcement:
Watts Bar Unit 1 Operating License Condition 2.F requires that the licensee implement and maintain in effect all provisions of the approved fire protection program(FPP) as described in the Fire Protection Report (FPR) for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). The FPP, Section 14.9, Emergency Battery Lighting Units, requires that the emergency battery lighting units provided for fire safe shutdown (FSSD) shall be operable whenever the illuminated associated FSSD equipment is required.
Contrary to the above, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). Specifically, the licensee failed to implement the requirements of the FPP, Section 14.9, Emergency Battery Lighting Units, by failing to ensure that work activities did not adversely affect the operability of Appendix R emergency lighting from February 3, 2011, to April 13, 2011. On April 13, 2011, the licensee took immediate action to establish compensatory actions and initiate corrective action to comply with the FPP.
Because this finding was of low safety significance (Green) and was entered into the licensees corrective action program as problem evaluation report (PER) 354437 with corrective actions documented in PER 341645. This violation is being treated as a non-cited violation (NCV), consistent with the NRC Enforcement Policy and is identified as NCV 05000390/2011003-01, Failure to Ensure the Operability of an Emergency Battery Lighting Unit in Accordance with the Approved Fire Protection Plan.
===.2
Introduction:
The inspectors identified a Green NCV of Technical Specification 5.7.1,===
Procedures, for the licensees failure to maintain post-fire safe shutdown procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, following a plant modification.
Specifically, an operator manual action for FSSD contained in AOI-30.2 C.36 could not be feasibly performed due to a change in physical plant configuration.
Description:
On April 13, 2011, with the plant in Mode 6 Refueling, the inspectors identified that in the Unit 2B 480 volt transformer room (Room 772.0-A11), the installation of new electrical conduits prevented the use of an emergency operating procedure use only eight-foot step ladder necessary to perform an operator manual action. The conduit was installed per design change notice (DCN) 53334-A in support of Unit 2 construction activities. The action required an operator to access a valve near the ceiling to perform an operator manual action in the event of a fire in Analysis Volume 36 (i.e., Room 737-A1A). Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, was an implementing procedure for the facility fire protection program as described in the FPR which specified the manual actions which may be required for fires potentially affecting safety equipment necessary to achieve and maintain post-fire safe shutdown.
Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Attachment 4, Local Area Operator (AUO) #4 Actions, specifies the required operator manual action to open room ventilation damper 2-FCO-30-246A. Outside fresh air cooling is necessary for operation of the air-cooled 480 volt transformers contained in the room. The operator manual action requires closing an instrument air valve (2-ISV-32-3434) near the ceiling in the event of a fire to fail open the associated damper. The inspectors notified TVA Fire Operations of the observation and verified that no previous compensatory measures were in place for the condition. TVA Fire Operations took immediate action to establish compensatory measures, including the erection of temporary scaffolding providing operator access to the instrument air valve. TVA Fire Operations also took immediate action to initiate corrective action to comply with Part II of the FPR, the FPP, Section 14.10, Fire Safe Shutdown Equipment.
Analysis:
The inspectors determined that the licensees failure to ensure that an operator manual action for FSSD could be feasibly performed under the current physical plant configuration was a performance deficiency. The performance deficiency was determined to be more than minor because it affected the protection against external events attribute (i.e., fire) of the Mitigating Systems cornerstone, in that it affected the objective of ensuring availability, reliability, and capability of systems that respond to initiating events. A fire in the plant locations associated with Analysis Volume 36 could potentially affect systems and components necessary to maintain the steam generator inventory control; long term decay heat removal; fire pumps; reactor coolant inventory control; reactor pressure control; containment heating, ventilation, and air conditioning; secondary side isolation; and containment integrity functions. Mitigating features are required to restore systems necessary for safe shutdown. Specifically, safe shutdown is achieved through the use of the B-train residual heat removal (RHR) and charging pumps, the TDAFW pump, and associated flow paths. The required mitigating features in the event of a fire in Analysis Volume 36 include manual operation of equipment required for safe shutdown. This includes restoration of room cooling to the Unit 2B 480 volt transformer room per Procedure AOI-30.2 C.36. Because the finding adversely affected, to some degree, the ability to carry out local operator actions required to achieve and maintain a FSSD condition following a severe fire, the inspectors completed a SDP Phase 1 analysis that indicated the finding was not a major degradation of FSSD capability and, therefore, was of very low significance. The conclusion of degradation significance was based on the procedure step in question was not a time-critical step.
The cause of the finding was directly related to the cross-cutting aspect of Work Activity Coordination in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately coordinate work activities, consistent with nuclear safety, to ensure that changes to the physical plant configuration would not adversely affect the feasibility of operator manual actions (H.3 (b)).
Enforcement:
Technical Specification 5.7.1, Procedures, requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, and fire protection program implementation. Regulatory Guide 1.33, Appendix A, Section 6, recommends procedures for combating emergencies such as plant fires.
Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, was an implementing procedure for the facility fire protection program.
Contrary to the above, from July 14, 2009 to April 13, 2011, the licensee failed to adequately maintain AOI-30.2 C.36 following implementation of a plant design change.
Specifically, a manual action contained in AOI-30.2 C.36 could not be feasibly performed due to a change in physical plant configuration which prevented the use of the required eight-foot step ladder to access a system valve. The licensee took immediate corrective action on April 13, 2011, to establish compensatory actions as a result of the conduit installation and initiate corrective action to comply with the FPP. Because this finding was of low safety significance (Green) and was entered into the licensees corrective action program as PER 356563, this violation is being treated as an NCV consistent with the NRC Enforcement Policy and is identified as NCV 05000390/2011003-02, Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Non-feasible Operator Manual Action.
===.3
Introduction:
The inspectors identified a Green NCV of the Unit 1 Operating License===
Condition 2.F for the licensees failure to store transient combustible materials in a safety-related/critical area of the auxiliary building in accordance with the approved FPP.
Specifically, approximately 38 gallons of hydrocarbon oil was stored inside the entrance labyrinth of the 1B charging pump room without an approved transient combustible evaluation, as required by the FPP.
Description:
On May 18, 2011, with the plant in Mode 3 Hot Standby following a refueling outage, the inspectors noted that no approved transient combustible evaluation was performed for the storage of a large quantity of oil in a safety-related charging pump room. A steel 55-gallon drum (unapproved container), with the removable lid secured, was partially obstructing the entrance of the 1B charging pump room. This area was not protected by the installed sprinkler system in the pump room. The inspectors later determined that the contents of the drum was approximately 38 gallons of new hydrocarbon oil placed in the room on or about April 21, 2011, for possible use in the charging pump during refueling outage maintenance. Per Part II of the FPR, the FPP, Section 10.0, Control of Combustibles, the use and handling of flammable/combustible gases and liquids are controlled in safety-related areas. Implementing procedure NPG-SPP-18.4.7, Control of Transient Combustibles, Section 3.2.1.J., specifies that flammable and combustible liquids shall be stored in approved storage rooms or storage cabinets when not in use. Since the oil was not in use, an approved transient combustible evaluation was required for storage in the 1B charging pump room. The inspectors notified TVA Fire Operations of the observation and verified that no approved transient combustible evaluation was performed for the storage of the oil. TVA Fire Operations took immediate action to remove the transient drum of oil from the 1B charging pump room to comply with the FPP.
Analysis:
The inspectors determined that the licensees failure to perform a transient combustible evaluation for the storage of a large quantity of oil in a safety-related charging pump room in accordance with the approved FPP, Section 10.0, Control of Combustibles, was a performance deficiency. The performance deficiency was determined to be more than minor because it affected the protection against external events attribute (i.e., fire) of the Mitigating Systems cornerstone, in that, it affected the objective of ensuring availability, reliability, and capability of systems that respond to initiating events. Because the finding increased the fire loading due to an increase in the volume of the predominant combustible material in the area by approximately 72 percent; the inspectors completed a SDP Phase 1 and Phase 2 analysis that indicated the finding was not a major degradation of fire prevention and administrative controls.
The cause of the finding was directly related to the cross-cutting aspect of Proper Work Planning in the Work Control component of the area of Human Performance, in that the licensee failed to appropriately plan work activities to minimize the risk associated with a large quantity of oil in a safety-related fire zone without compensatory measures. (H.3 (a)).
Enforcement:
Watts Bar Unit 1 Operating License Condition 2.F requires that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). The FPP, Section 10.0, Control of Combustibles, requires that the use and handling of flammable/combustible gases and liquids are controlled in safety-related areas. Implementing procedure NPG-SPP-18.4.7, Control of Transient Combustibles, Section 3.2.1.J., specifies that flammable and combustible liquids shall be stored in approved storage rooms or storage cabinets when not in use.
Contrary to the above, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FPR for the facility, as approved in Supplements 18 and 19 of the safety evaluation report (NUREG-0847). Specifically, the licensee failed to implement the requirements of the FPP, Section 10.0, Control of Combustibles, by failing to perform a transient combustible evaluation for the storage of a large quantity of oil in a safety-related charging pump room from April 21, 2011, to March 18, 2011. On March 18, 2011, the licensee took immediate action to remove the transient drum of oil from the 1B charging pump room to comply with the FPP. Because this finding was of low safety significance (Green) and was entered into the licensees corrective action program as PER 371383 and PER 380910, this violation is being treated as an NCV consistent with the NRC Enforcement Policy and is identified as NCV 05000390/2011003-03, Failure to Perform a Transient Combustible Evaluation for Storage of Oil in a Safety Related Area in Accordance with the Approved Fire Protection Plan.
1R06 Flood Protection Measures
Auxiliary Building
a. Inspection Scope
The inspectors reviewed the medium energy line break analysis of unisoloble pipe breaks in the auxiliary building to verify that the flood protection barriers and equipment were being maintained consistent with the Updated Final Safety Analysis Report (UFSAR). Additional documents reviewed are listed in the Attachment. This does not constitute an inspection sample because it is a follow-up of a previous issue.
b. Findings
Introduction.
The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, involving the failure to adequately translate design output into plant procedures.
Description.
During a baseline inspection of the licensees flooding mitigation equipment and procedures, the inspectors determined that a portion of the design output of WBNOSG4099, Moderate Energy Line Break Flooding Study was not translated into plant procedures. Specifically, Appendix I, table I3 states that in the event of a non-isolable leak in the RWST piping connecting to the ECCS system, that a pump of 306 gpm capacity would be installed within 10.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. No procedure existed that would implement this requirement.
Analysis:
The inspectors determined that the failure to have a procedure for an internal flooding event in the Auxiliary Building was a performance deficiency. This performance deficiency was determined to be greater than minor because if it had been left uncorrected it would have the potential to lead to a more significant safety concern i.e.,
longer risk exposure to an unmitigated internal flooding event. The inspectors evaluated the finding using the SDP in accordance with IMC 0609, Significance Determination Process, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. The inspectors determined the finding was potentially greater than very low safety significance because as described in the Mitigation System Cornerstone, the finding screened as potentially risk significant due to a seismic, flooding or severe weather initiating event. Consequently a Phase 3 analysis was required. The analysts determined the lack of internal flooding mitigation due to a RWST pipe rupture was of very low risk significance i.e., Green. The main contributors to the low risk results were:
1) the low likelihood of a spontaneous pipe rupture in a low/medium pressure system, and 2) the limited risk consequences of damaging the components affected by the postulated flood i.e., the containment spray pumps and the RHR pump room coolers.
Further, the analysts determined that the precursor event (a piping rupture) would not cause an initiating event (e.g., loss of offsite power, main steam line break).
Consequently the analyst assumed that the worst case scenario would be a forced reactor shutdown due to the loss of inventory from the RWST. The cause of the finding extends back to original plant licensing. Therefore, it is not related to current performance and is not assigned a cross-cutting aspect.
Enforcement.
Title 10 CFR Part 50, Appendix B, Criterion III requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee failed to translate a portion of design document WBNOSG4099, Moderate Energy Lie Break Flooding Study into a procedure that would mitigate certain instances of internal plant flooding. The safety significance of this inspection finding has been characterized by the Significance Determination Process phase 3 and determined to be Green or of very low risk significance. Because this finding was of low safety significance (Green) and has been entered in the licensees corrective action program as PER 341568, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy: NCV 05000390/2011003-04, Failure to Translate Moderate Energy Line Break Study Output into a Plant Procedure.
1R08 Inservice Inspection (ISI) Activities (IP 71111.08P, Unit 1)
.1 Non-Destructive Examination (NDE) Activities and Welding Activities
a. Inspection Scope
From April 11-15, 2011, the inspectors reviewed the implementation of the licensees Risk Informed In-service Inspection (ISI) program for monitoring degradation of the reactor coolant system (RCS) boundary and risk significant piping boundaries. The inspectors activities consisted of an on-site review of Non-Destructive Evaluation (NDE)and welding activities to evaluate compliance with the applicable edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),
Section XI (Code of record: 2000 Edition through the 2001 Addenda), and that indications and defects (if present) were appropriately evaluated and dispositioned in accordance with the requirements of the ASME Code,Section XI acceptance standards.
The inspectors review of NDE activities specifically covered examination procedures, NDE reports, equipment and consumables certification records, personnel qualification records, and calibration reports (as applicable) for the following examinations:
- Visual Testing (VT) examination of 555-18-18-2 Containment Spray support The inspectors review of welding activities specifically covered the welding activity listed below in order to evaluate compliance with procedures and the ASME Code. The inspectors reviewed the work order, repair and replacement plan, weld data sheets, welding procedures, procedure qualification records, welder qualification records, and NDE reports.
- Replace valve 1-RFV-070-521 for welds 1-070A-T019-15 and 1-070A-T019-16
b. Findings
No findings were identified.
.2 PWR Vessel Upper Head Penetration (VUHP) Inspection Activities
a. Inspection Scope
Watts Bar Unit 1 completed bare metal visual examination of the RPV Head Penetrations (N-729-1) this outage and bare metal visual examination of the RPV Bottom Head Nozzle Penetrations (N-722 item) during October 2009 outage pursuant to 10 CFR 50.55a(g)(6)(ii)(D).
The inspectors reviewed records of the visual examination (VT-2) conducted on the Unit 1 reactor vessel head to evaluate if the activities were conducted in accordance with the requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D), per Note 4, table 1, reactor upper vessel head under the insulations.
Specifically, the inspectors reviewed the following documentation:
- Evaluated if the required visual examination scope/coverage was achieved and limitations (if applicable) were recorded in accordance with the licensee procedures.
- Evaluated if the licensees criteria for visual examination quality and instructions for resolving interference and masking issues were adequate.
The licensee did not perform any weld repairs to vessel head penetrations since the beginning of the last Unit 1 outage. Therefore, no NRC review was completed for this inspection procedure attribute.
b. Findings
No findings were identified.
.3 Boric Acid Corrosion Control (BACC) Inspection Activities
a. Inspection Scope
The inspectors reviewed the licensees BACC program activities to ensure implementation with commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary, and applicable industry guidance documents. Specifically, the inspectors performed an on-site record review of procedures and the results of the licensees containment walk-down inspections performed during the Unit 1 Spring 2011 outage. The inspectors also interviewed the BACC program owner and conducted an independent walk-down of the reactor building to evaluate compliance with licensees BACC program requirements and verify that degraded or non-conforming conditions, such as boric acid leaks identified during the containment walk-down, were properly identified and corrected in accordance with the licensees BACC and Corrective Action Programs.
The inspectors also evaluated the corrective actions for any degraded reactor coolant system components against ASME Code Section XI and other licensee committed documents:
- WO 110770187 1-PDIS-62-97 Differential pressure gauge
- WO 111067817 1-ISIV-63-386C Panel 1-L-136 leak The inspectors reviewed a sample of engineering evaluations completed for evidence of boric acid found on systems containing borated water to verify that the minimum design code required section thickness had been maintained for the affected components. The inspectors selected the following evaluations for review:
- PER 217371 CVCS Seal Water Injection Filter A differential pressure meter
- PER 234520 Panel 1-6-136 at test tee connection
b. Findings
No findings were identified.
.4 Steam Generator (SG) Tube Inspection Activities
a. Inspection Scope
No SG eddy current testing (ECT) or secondary side visual exams were scheduled for this outage. The inspectors reviewed the licensees steam generator degradation assessment for compliance with the EPRI Pressurized Water Reactor Steam Generator Examination Guidelines, Rev.7.
b. Findings
No findings were identified.
.5 Identification and Resolution of Problems
a. Inspection Scope
The inspectors performed a review of ISI-related problems, including welding, BACC, and SGISI and that were identified by the licensee and entered into the corrective action program as Condition Reports (CRs). The inspectors reviewed the CRs to confirm that the licensee had appropriately described the scope of the problem and had initiated corrective actions. The review also included the licensees consideration and assessment of operating experience events applicable to the plant. The inspectors performed this review to ensure compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment.
b. Findings
No findings were identified
1R11 Licensed Operator Requalification
a. Inspection Scope
Inspectors conducted sampling of classroom lectures, simulator training, and simulator testing of four operating crews. This training and testing was in preparation for the replacement of the currently existing analog main feedwater control system with a digital feedwater control system. This system will be implemented on Unit 2, which is currently under construction, and on Unit 1 at its next refueling outage in the fall of 2012. Current licensee plans are for currently licensed operators to operate the digital system on Unit 2 prior to the next Unit 1 outage. Changes to the Unit 1 reference simulator to include the digital feedwater control system will also occur prior to the next Unit 1 outage. Due to the significance of the change, and that for a period of time operators will be manipulating both the analog and digital system, inspectors performed a detailed review of the digital feedwater control system training and testing.
The inspectors also attended the critique to assess the effectiveness of the licensee evaluators and to verify that licensee-identified issues were comparable to issues identified by the inspector.
The inspectors specifically evaluated the following attributes related to the operating crews performance:
- Clarity and formality of communication
- Ability to take timely action to safely control the unit
- Prioritization, interpretation, and verification of alarms
- Correct use and implementation of abnormal operating instructions (AOIs) and emergency operating instructions (EOIs)
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the two performance-based problems listed below. A review was performed to assess the effectiveness of maintenance efforts that apply to scoped SSCs and to verify that the licensee was following the requirements of TI-119, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting 10 CFR 50.65, and NPG-SPP-03.4, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting 10 CFR 50.65. Reviews focused, as appropriate, on:
- (1) appropriate work practices;
- (2) identification and resolution of common cause failures;
- (3) scoping in accordance with 10 CFR 50.65;
- (4) characterization of reliability issues;
- (5) charging unavailability time;
- (6) trending key parameters;
- (7) 10 CFR 50.65 (a)(1) or (a)(2) classification and reclassification; and
- (8) the appropriateness of performance criteria for SSCs classified as (a)(2) or goals and corrective actions for SSCs classified as (a)(1).
- TDAFW pump work practices associated with turbine casing, bearing, and governor maintenance
- Review of the main steam vault room ventilation system a(1) action plan
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors evaluated, as appropriate, for the two work activities listed below:
- (1) the effectiveness of the risk assessments performed before maintenance activities were conducted;
- (2) the management of risk;
- (3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and
- (4) that maintenance risk assessments and emergent work problems were adequately identified and resolved. The inspectors verified that the licensee was complying with the requirements of 10 CFR 50.65 (a)(4); SPP-7.0, Work Control and Outage Management; NPG-SPP-07.1, One Line Work Management; and TI-124, Equipment to Plant Risk Matrix. This inspection satisfied two inspection samples for Maintenance Risk Assessment and Emergent Work Control.
- PRA evaluation for emergent work on C-S component cooling system (CCS) pump seals with 2B EDG, G ERCW pump and B main control room chiller OOS
- PRA evaluation of work week 811 which included B auxiliary air compressor planned maintenance and containment air return fan planned maintenance while 1B EDG was OOS for planned maintenance.
b. Findings
No findings were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed four operability evaluations affecting risk-significant mitigating systems, listed below, to assess, as appropriate:
- (1) the technical adequacy of the evaluations;
- (2) whether continued system operability was warranted;
- (3) whether the compensatory measures, if involved, were in place, would work as intended, and were appropriately controlled;
- (4) where continued operability was considered unjustified, the impact on TS Limiting Conditions for Operation (LCOs) and the risk significance in accordance with the significant determination process (SDP). The inspectors verified that the operability evaluations were performed in accordance with NPG-SPP-03.1, Corrective Action Program.
- Functional evaluation for PER 335459, Seismic qualification of replacement Heinemann molded case circuit breakers in the 120vac vital instrument power boards
- Functional evaluation for PER 366842, 1-FCV-001-0004, Main Steam Isolation Valve spring preload greater than allowed per design
- Functional evaluation for PER 366973, 1-PMP-003-0001A-S, TDAFW, pump to turbine alignment not per acceptance criteria
- Functional evaluation for PER 214379, Potential impact of debris in the condensate storage tank on the Auxiliary Feed Water System (URI 05000390/2009002-01)
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed one permanent plant modification to verify that design output controls were adequate, post-modification testing was satisfactory, and affected operational procedures and licensing documents were identified and revised accordingly. Additional documents reviewed are listed in the Attachment.
- DCN-55076A-STG4, Replace 2B-B Diesel Generator Battery Charger
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed six post-maintenance test procedures and/or test activities, (listed below) as appropriate, for selected risk-significant mitigating systems to assess whether:
- (1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
- (2) testing was adequate for the maintenance performed;
- (3) acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
- (4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
- (5) tests were performed as written with applicable prerequisites satisfied;
- (6) jumpers installed or leads lifted were properly controlled;
- (7) test equipment was removed following testing; and
- (8) equipment was returned to the status required to perform its safety function. The inspectors verified that these activities were performed in accordance with NPG-SPP-06.9, Testing Programs; NPG-SPP-06.3, Pre-/Post-Maintenance Testing; and NPG-SPP-07.1, On Line Work Management.
- WO 10-815728-000, 1-SI-63-905, Boron injection check valve flow test during refueling outages
- WO 10-812392-000, Operator maintenance on 1-FCV-63-3, WO 110790022 - DCN 51659, Spring pack replacement on 1-FCV-63-156
- WO 1100790050 on 1-FCV-63-22 and WO 110790024 on 1-FCV-63-157 - DCN 51659, Spring pack replacement (on both valves)
- WO 10-816046, 1-SI-3-923B, Auxiliary feedwater pump 1B-B comprehensive test; PMT for 1-PCV-3-132 - DCN 57975
- WO 10-815777-000, Replacement of EGR and servo valve for TDAFW pump PMT per 1-SI-3-923-5, Auxiliary feedwater pump 1A-S comprehensive pump test
b. Findings
No findings were identified
1R20 Refueling and Outage Activities
a. Inspection Scope
The inspectors reviewed the outage risk control plan for the upcoming Unit 1 Cycle 10 (U1C10) refueling outage (RFO) to assess whether the licensee had appropriately considered risk, industry experience, and previous site-specific problems, and to also confirm that the licensee had mitigation/response strategies for losses of key safety functions. Additional documents reviewed are listed in the Attachment.
The licensee began its U1C10 RFO on April 4, 2011. From that date through the end of the RFO, the inspectors observed portions of the shutdown, cool down, defueling, maintenance activities, refueling, heatup, and startup to verify that the licensee maintained defense-in-depth (DID) commensurate with the outage risk plan and applicable TS. During the outage, the inspectors also reviewed the licensees control of heavy loads to ensure the licensee was properly handling heavy loads in areas where a load drop could impact fuel in the reactor core or equipment that would be required to achieve safe shutdown. Inspectors observed the initial head lift to verify that it complied with the safe load path specified in licensee procedures.
The inspectors monitored licensee controls over the outage activities listed below. In addition, the inspectors reviewed the licensees CAP to ensure that the licensee was identifying equipment alignment problems and that they were properly addressed for resolution.
- Licensee configuration management, including daily outage reports, to evaluate Defense in Depth (DID) commensurate with the outage safety plan and compliance with the applicable TS when taking equipment out of service
- Installation and configuration of reactor coolant instruments to provide accurate indication and an accounting for instrument error
- Controls over the status and configuration of electrical systems and switchyard to ensure that TS and outage safety plan requirements were met
- Licensee implementation of clearance activities to ensure equipment was appropriately configured to safely support the work or testing
- Decay heat removal processes to verify proper operation and that steam generators, when relied upon, were a viable means of backup cooling
- Controls to ensure that outage work was not impacting the ability to operate the spent fuel pool cooling system during and after-core offload
- Reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss
- Reactivity controls to verify compliance with TS and that activities which could affect reactivity were reviewed for proper control within the outage risk plan.
- Licensee control of heavy loads while moving the reactor vessel head from the vessel to the head stand
- Refueling activities for compliance with TS to verify proper tracking of fuel assemblies from the spent fuel pool to the core and to verify foreign material exclusion was maintained
- Heatup and startup activities to verify that TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites for mode changes were met prior to changing modes or plant conditions; RCS integrity verified by reviewing RCS leakage calculations; and containment integrity verified by reviewing the status of containment penetrations and containment isolation valves
- Containment closure activities, including a detailed containment walkdown prior to startup, to verify no evidence of leakage and that debris had not been left which could affect the performance of the containment sump or ice condenser
- Licensee management of fatigue by reviewing schedules, time sheets, and waivers to manage fatigue and associated administrative controls.
b. Findings
No findings were identified
1R22 Surveillance Testing
a. Inspection Scope
The inspectors witnessed eight surveillance tests and/or reviewed test data of selected risk-significant SSCs, listed below, to assess, as appropriate, whether the SSCs met the requirements of the TS; the UFSAR; SPP-8.0, Testing Programs; NPG-SPP-06.9.2, Surveillance Test Program; and SPP-9.1, ASME Section XI. The inspectors also determined whether the testing effectively demonstrated that the SSCs were operationally ready and capable of performing their intended safety functions.
In-Service Test:
- WO 112106660, 0-SI-67-922-B, WBN-0-PMP-067-0051-B, Emergency Raw Cooling Water F-B Preservice Test
- WO 10-815958-000, 1-SI-63-906, Safety Injection Check Valve Full-Flow Testing During Refueling Outages
- WO 112210948, 1-SI-63-907, Residual Heat Removal Hot Leg and Cold Leg Injection Check Valve Testing During Refueling Containment Isolation Valve (CIV)
- WO 112013395, 1-SI-67-701A, Containment Isolation Valve Local Leak Rate Test Train-A Upper Compartment ERCW Ice Condenser
- WO 10-815970-000, 1-SI-61-4, 40 Months Ice Basket Structural Integrity Visual Inspection Other Surveillances
- WO 112165628, 1-SI-0-10, Shutdown Margin
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
On June 1, 2011, the inspectors observed a licensee-evaluated emergency preparedness drill, listed below, to verify that the emergency response organization was properly classifying the event in accordance with emergency plan implementing procedure (EPIP)-1, Emergency Plan Classification Flowchart, and making accurate and timely notifications and protective action recommendations in accordance with EPIP-2, Notification of Unusual Event; EPIP-3, Alert; EIPIP-4, Site Area Emergency; EPIP-5, General Emergency; and the Radiological Emergency Plan. In addition, the inspectors verified that licensee evaluators were identifying deficiencies and properly dispositioning performance against the performance indicator criteria in Nuclear Energy Institute (NEI)99-02, Regulatory Assessment Performance Indicator Guideline.
- A pressurizer safety valve failing full open results in a loss of subcooling leading to an Alert classification followed by a reactor coolant system (RCS) loss of coolant accident (LOCA) and the failure of containment spray capability results in an elevated Containment pressure requiring Site Area Emergency classification followed by a condition where a rapid unexplained decrease in Containment pressure follows an initial pressure increase leading to a General Emergency
b. Findings
No findings were identified.
RADIATION SAFETY
(RS)
Cornerstones: Occupational Radiation Safety (OS)
2RS1 Radiological Hazard Assessment and Exposure Control
a. Inspection Scope
Hazard Assessment and Instructions to workers: During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas and high radiation areas (HRAs) established within the radiologically controlled area (RCA).
The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed and verified survey records for several plant areas including surveys for alpha emitters, airborne radioactivity, and gamma radiation surveys with a range of dose rate gradients.
The inspectors also discussed changes to plant operations with Radiation Protection (RP) supervisors that could contribute to changing radiological conditions since the last inspection. The inspectors attended a pre-job discussion and reviewed several radiation work permits (RWP) to assess communication of radiological control requirements and current radiological conditions to workers.
Hazard Control and Work Practices: The inspectors evaluated access barrier effectiveness for selected Locked High Radiation Area (LHRA) and Very High Radiation Area (VHRA) locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with RP supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool were reviewed and discussed. Established radiological controls (including airborne controls) were evaluated for selected tasks including work in auxiliary building HRAs, and radwaste processing and storage. In addition, licensee controls for areas where dose rates could change significantly as a result of plant shutdown and refueling operations were reviewed and discussed.
Occupational workers adherence to selected RWPs and HP technician (HPT)proficiency in providing job coverage was evaluated through direct observations and interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker stay times were evaluated against area radiation survey results for reviewed RWPs.
Control of Radioactive Material: The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.
Problem Identification and Resolution: Summaries of PERS associated with radiological hazard assessment and control were reviewed and assessed for trends and recurrence.
These summaries contained the full problem description and were broadly categorized as exposure controls, radiation monitoring and surveys, radiological events-radworkers and radiological events-technicians. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure NPG-SPP-3.1, Corrective Action Program, Rev. 1. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results.
Radiation protection activities were evaluated against the requirements of UFSAR Section 12; TS Sections 5.7 Procedures, Programs and Manuals and 5.11 High Radiation Areas; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS1 of the Attachment.
The inspectors completed the one specified line-item sample detailed in IP 71124.01.
b. Findings
No findings were identified.
2RS2 As Low As Reasonably Achievable (ALARA)
a. Inspection Scope
ALARA Program Status The inspectors reviewed and discussed plant exposure history and current trends including the sites three-year rolling average (TYRA) collective exposure history for calendar year (CY) 2007 through CY 2009. Current and proposed activities to manage site collective exposure and trends regarding collective exposure were evaluated through review of previous TYRA collective exposure data and review of the licensees 5-year ALARA program implementing plan. Current ALARA program guidance and recent changes, as applicable, regarding estimating and tracking exposure were discussed and evaluated.
Radiological Work Planning The inspectors reviewed planned work activities and their collective exposure estimates for Unit 1 Refueling Outage 10 (U1RF10). Work activities, exposure estimates and mitigation activities were reviewed for selected U1RF10 work activities that included thimble tube withdrawal, insertion and replacement and diving in the transfer canal to repair fuel transfer system equipment. For the selected tasks, the inspectors reviewed dose mitigation actions and established dose goals. Current collective dose data for selected tasks were compared with established estimates and, where applicable, changes to established estimates were discussed with responsible licensee ALARA planning representatives. The inspectors observed the preparations for and subsequent execution of a primary filter change out which allowed the inspectors to assess the radiation worker and radiation protection technician work practices. The inspectors reviewed previous post-job reviews conducted for the previous U1RF9 and verified that the items were entered into the licensees CAP for evaluation.
Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed select ALARA work packages and discussed assumptions with responsible planning personal regarding the bases for the current estimates. The licensees dose tracking was reviewed for adequacy with regard to identifying abnormal dose trends and dose distributions. Selected ALARA Packages with work scope additions and/or higher than expected dose rates were selected from the previous outage to review the in-progress and post job review process and the process used to adjust cumulative exposure estimates.
Source Term Reduction and Control The inspectors reviewed historical dose rate trends for shutdown chemistry, cleanup, and resultant chemistry and RP trend-point data against the latest U1RF10 data. The inspectors discussed the benefits of the various source term reduction methods being employed such as ultrasonic fuel cleaning, zinc injection, and macro porous resins. The inspectors also inquired about the initiatives that would be incorporated into Unit 2.
Problem Identification and Resolution The inspectors reviewed and discussed selected PERs associated with ALARA program implementation. The reviewed items included PERs, self-assessments, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure NPG-SPP- 03.1, Corrective Action Program, Rev. 1.
The licensees ALARA program activities and results were evaluated against the requirements of UFSAR Section 12; TS Sections 5.7 Procedures, Programs and Manuals and 5.11 High Radiation Areas; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS2 of the report
.
The inspectors completed all specified line-items detailed in IP 71124.02 (sample size of 1).
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
Plant Airborne Radioactivity Controls and Mitigation: The inspectors reviewed the plants Updated Final Safety Analysis Report (UFSAR) to identify areas with the potential for elevated airborne radionuclide concentrations. Selected engineering controls for selected areas of the plant were discussed with radiation protection and operations staff to include the Radwaste Building, Spent Fuel Pool, and the Auxiliary Building. In addition, selected licensee documents including Technical Specifications, UFSAR, design basis documents, Emergency Response Organization rosters, and procedures associated with plant airborne radioactivity controls and monitoring, and with respiratory protection program and emergency planning implementation were reviewed and discussed with cognizant licensee representatives.
Engineering Controls: The inspectors reviewed the use of temporary and permanent engineering controls to mitigate airborne radioactivity for selected work activities. The inspectors observed the use of high efficiency particulate air ventilation and vacuums to control contamination during surface disturbing work. Air sampling analysis results and radiological surveys for selected jobs in contaminated areas with the potential for producing airborne conditions were also reviewed. The inspectors evaluated the effectiveness of continuous air monitors and air samplers placed in selected work area breathing zones to provide indication of increasing airborne levels.
Use of Respiratory Protection Equipment: The inspectors reviewed the use of respiratory protection devices to limit the intake of radioactive material. This included review of devices used for routine tasks and devices stored for use in emergency situations. Selected Self-Contained Breathing Apparatus (SCBA) units and negative pressure respirators (NPR) staged for routine and emergency use in the Main Control Room and other locations were inspected for material condition, SCBA bottle air pressure, number of units, and number of spare masks and air bottles available. The inspectors reviewed maintenance records for selected SCBA units and evaluated SCBA and NPR compliance with National Institute for Occupational Safety and Health certification requirements. The inspectors also reviewed records of air quality testing for supplied-air devices and SCBA bottles.
The inspectors reviewed ALARA evaluations for the use of respiratory protection devices for selected work activities conducted during the previous refueling outage.
The inspectors verified the licensee had procedures in place to ensure that the use of respiratory protection devices was ALARA when engineering controls were not practicable. Due to limited respirator use during the period of inspection, the inspectors reviewed training curricula for various types of respiratory protection devices with cognizant licensee training representatives. In addition, the inspectors observed a training session for select maintenance workers for SCBA requalifications. Also, selected security guards, control room operators and radiation protection personnel were interviewed on the use of the devices to include SCBA bottle change-out and use of corrective lens inserts. Respirator qualification records and medical fitness cards were reviewed for selected emergency responder personnel in the Maintenance, Operations, Security, Chemistry and RP departments. In addition, qualifications for individuals responsible for testing and repairing SCBA vital components were evaluated through review of selected training records.
The inspectors verified that the licensee has procedural requirements in place for evaluating air samples for the presence of alpha emitters and reviewed airborne radioactivity and contamination survey records for several plant areas to ensure air samples are screened and evaluated per the procedure requirements.
The inspectors walked-down the respirator issue and storage locations and verified that the equipment was appropriately stored and maintained. Records of monthly and quarterly inventory and inspection of the equipment were also reviewed by the inspectors. The inspectors discussed the process for issuing respirators, and verified that selected individuals qualified for respirator and/or self-contained breathing apparatus (SCBA) use had completed the required training, fit-test, and medical evaluation.
In addition, the inspectors walked-down the compressor used for filling SCBA bottles and reviewed records of Grade D air testing for the compressor and instrument air systems. The ability to fill and transport bottles to the control room during an emergency was assessed by the inspectors.
Self-Contained Breathing Apparatus for Emergency Use: The inspectors reviewed the status and surveillance records of SCBAs staged for in-plant use during emergencies through review of records and walk-down of SCBA staged in the control room, technical support center, and operations support center. The walk-down verified the appropriate number of SCBA kits were staged as specified by the emergency plan, appropriate mask sizes and types available for use, and, through interviews, that users were knowledgeable of storage locations of SCBA, spare masks, and vision correction, as well as how to don and use the equipment. Selected maintenance records for SCBA units and air cylinder hydrostatic testing documentation were reviewed.
Problem Identification and Resolution: Licensee CAP documents associated with the control and mitigation of in-plant radioactivity were reviewed and assessed. This included review of selected PERs related to use of respiratory protection devices including SCBA. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with procedure NPG-SPP-03.1, Corrective Action Program, Rev. 1. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Licensee CAP documents reviewed are listed in Section 2RS3 of the Attachment.
Radiation protection activities were evaluated against the requirements UFSAR Section 12; 10 CFR Parts 19 and 20; Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection; and approved licensee procedures. Documents reviewed during the inspection are listed in Section 2RS3 of the Attachment.
The inspectors completed all specified line-items detailed in IP 71124.03 (sample size of 1).
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation
a. Inspection Scope
Radioactive Waste System Walkdown, Waste Characterization and Classification, and Radioactive Material Storage The inspectors walked down accessible sections of the liquid radwaste system to assess material condition and conformance of equipment with system design diagrams. This included the Radwaste Building containing storage tanks, areas containing abandoned equipment, the Radwaste Control Panel, and the resin processing area. The inspectors discussed the function of radwaste components, as well as the mixing and dewatering of resins with the radwaste contractor. The inspectors discussed possible changes to the radwaste processing systems with the contractor, who indicated that no changes to the systems have been made. The inspectors also observed the physical condition and labeling of several storage containers within the radwaste building.
The inspectors reviewed the 2010 Radioactive Effluent Release Report and the 2010-2011 radionuclide characterization and classification for the Dry Active Waste (DAW)and resin waste streams. The inspectors evaluated analyses for hard-to-detect nuclides, reviewed the use of scaling factors, and examined quality assurance (QA) comparison results between licensee waste stream characterizations and outside laboratory data.
The inspectors also reviewed how changes to plant operational parameters were taken into account in waste characterization.
Shipment Preparation and Records The inspectors directly observed preparation of the shipment of a High Integrity Container (HIC) containing Low Specific Activity (LSA) bead resin. The inspectors noted package markings and placarding, and interviewed the shipping technician regarding Department of Transportation (DOT) regulations. In addition, training records for selected individuals currently qualified to ship radioactive material were reviewed for compliance with 49 CFR Part 172 Subpart H.
Four licensee shipping records were reviewed for consistency with licensee procedures and compliance with NRC and DOT regulations. This included review of emergency response information, waste classification, radiation survey results, information on the waste manifest, and the authorization of the receiving licensee to receive shipments.
Identification and Resolution of Problems The inspectors reviewed selected PERs in the area of radwaste/shipping. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with procedure NPG-SPP-03.1, Corrective Action Program, Rev. 1.
The observed storage of radioactive material waste was reviewed for compliance with the labeling and storage requirements of 10 CFR Part 20. Waste stream characterization analyses and how changes to plant parameters were taken into account, were reviewed for compliance with the regulations in 10 CFR Part 61 and guidance provided in the Branch Technical Position on Waste Classification (1983).
Transportation program implementation was reviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178, as well as the guidance provided in NUREG-1608. Licensee documents reviewed are listed in Section 2RS8 of the
.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee submittals for the two PIs listed below. To verify the accuracy of the PI data reported during the periods listed, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Revision 5, were used to verify the basis in reporting for each data element.
- RCS Leakage
- Safety System Functional Failures Occupational Radiation Safety Cornerstone: The inspectors reviewed Performance Indicator (PI) data collected from October 1, 2009, through March 30, 2011, for the Occupational Exposure Control Effectiveness PI. For the reviewed period, the inspectors assessed CAP records to determine whether HRA, VHRA, or unplanned exposures, resulting in TS or 10 CFR 20 non-conformances, had occurred during the review period. In addition, the inspectors reviewed selected personnel contamination event data, internal dose assessment results, and ED alarms for cumulative doses and/or dose rates exceeding established set-points. The reviewed data were assessed against guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline,"
Rev. 6. The reviewed documents relative to these PI reviews are listed in Sections 2RS1 of the Attachment.
Public Radiation Safety Cornerstone The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from June 2010, through May 2011. For the assessment period, the inspectors reviewed cumulative and projected doses to the public and PER documents related to Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual issues.
The reviewed documents relative to this PI are listed in Section 4OA1 of the Attachment.
b. Findings
No findings were identified.
4OA2 Identification & Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program (CAP)
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by reviewing daily PER summary reports and attending daily PER review meetings.
.2 Semi-Annual Review to Identify Trends
a. Inspection Scope
As required by IP 71152, Identification and Resolution of Problems, the inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on human performance trends, licensee trending efforts, and repetitive equipment and corrective maintenance issues. The inspectors also considered the results of the daily inspector CAP item screening discussed in Section 4OA2.1. The inspectors review nominally considered the six-month period of January 2011 through June 2011, although some examples expanded beyond those dates when the scope of the trend warranted.
b. Observations No findings were identified. However, both the inspectors and the licensee identified an increasing number of instances where transient combustibles were not analyzed, Appendix R lighting was broken or the illumination misdirected, and fire doors with various discrepancies up to and including inoperablitiy. See Sections 1R05 and 4OA7 for additional details. An additional trend was observed that the licensee was increasingly identifying issues below the regulatory threshold in the areas of risk assessment, Operations performance and fire protection.
.3 Annual Sample: Corrective actions associated with PER 8733 Reactor Cavity Leakage
a. Inspection Scope
The inspectors reviewed the plan and implementation of corrective actions for reactor cavity leakage, which were documented in PER 8733.
b. Findings and Observations
During containment walkdowns in refueling outage RF10, inspectors noted leakage on the order of 2 to 3 gpm from the reactor cavity tell-tale drain valves which were open and routed to a sump. Follow-up of this issue indicated that this was a previously identified problem. The reactor cavity leakage was documented in PER 8733 on September 19, 2003 with the following description: During flood up to refuel the cavity liner was noted to have about 2 to 3 GPM leakage. This is a repeat problem from other outages.
Inspectors reviewed the PER and found that it had been closed to work order 03-016131-000 on October 22, 2004. Review of the work order indicated that it has remained open with a status of INPLNG (in planning) with no work credited to it.
However, actions have been taken on other work orders to apply strippable coatings to the reactor cavity walls.
The original 2003 plan was to coat the lower reactor cavity to a level of six feet with a strippable coating and measure leakage. Based on poor results, the next outage, the coating was raised to the lower eight feet. Eight feet also proved to be inadequate and the licensee decided to go to 10 feet the following outage (the outage previous to this reporting period). Observations were that the leak was down to pencil size. As noted above, the original leakage observed in 2003 was commensurate with the leakage observed by the inspectors. That is, no improvement in the intervening eight years.
The inspectors were unable to verify the extent of the coating for this most recent outage as the licensee has been unable to produce an owner of the issue that would know the status. The licensee is identifying a new owner for this issue for follow-up.
No findings were identified.
4OA3 Event Follow-up
.1 Reactor Trip Due to Voltage Regulator Failure
Inspectors responded to the site on May 29, due to an automatic trip of the reactor which was caused by a card failure in a newly installed voltage regulator. The trip was uncomplicated. The cards were replaced and the unit was returned to service where it operated at or near 100 percent. All systems/components behaved as expected.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings were identified.
.2 (Closed) Temporary Instruction (TI) 2515/183, Follow-up to Fukushima Daiichi Nuclear
Station Fuel Damage Event
a. Inspection Scope
Inspection activities for TI 2515/183 were previously completed and documented in inspection report 05000390/2011009, and this TI is considered closed at Watts Bar; however, TI 2515/183 will not expire until June 30, 2012. The information gathered while completing this temporary instruction was forwarded to the Office of Nuclear Reactor Regulation for review and evaluation.
b. Findings
No findings were identified.
.3 (Closed) NRC TI 2515/184, Availability and Readiness Inspection of Severe Accident
Management Guidelines (SAMGs)
a. Scope
On May 27, 2011, the inspectors completed a review of the licensees severe accident management guidelines (SAMGs), implemented as a voluntary industry initiative in the 1990s, to determine
- (1) whether the SAMGs were available and updated,
- (2) whether the licensee had procedures and processes in place to control and update its SAMGs,
- (3) the nature and extent of the licensees training of personnel on the use of SAMGs, and
- (4) licensee personnels familiarity with SAMG implementation.
The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichi fuel damage event in Japan. Plant-specific results for Watts Bar Station were provided as an Enclosure to a memorandum to the Chief, Reactor Inspection Branch, Division of Inspection and Regional Support, dated June 02, 2011 (ML111530328).
b. Findings
No findings were identified.
.4 (Closed) TI 2515/179 Verification of Licensee Responses to NRC Requirement for
Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)
a. Scope
The inspectors performed the TI concurrent with IP 71124.01 Radiation Hazard
Analysis.
The inspectors reviewed the licensees source inventory records and identified the sources that met the criteria for reporting to the NSTS. The inspectors visually identified the sources contained in various calibration systems and verified the presence of the source by direct radiation measurement using a calibrated portable radiation detection survey instrument. The inspectors reviewed the physical condition of the irradiation device. The inspectors reviewed the licensees procedures for source receipt, maintenance, transfer, reporting and disposal. The inspectors reviewed documentation that was used to report the sources to the NSTS. Documents reviewed are listed in sections 2RS1 of the Attachment.
b. Findings
No findings were identified. This completes the Region II inspection requirements.
4OA6 Meetings, including Exit
.1 Exit Meeting Summary
On April 15, 2011, the inspectors discussed the results of the onsite radiation protection inspection with Mr. Don Grissette, Site Vice President, and other responsible staff. The inspectors noted that no personally identifiable information or proprietary information had been provided and if any was identified in subsequent document review that it would be properly destroyed.
On June 10, 2011, the inspectors discussed preliminary results of the onsite radiation protection inspection with Mr. D. Grissette, Site Vice President, and other responsible staff. The inspectors noted that no personally identifiable information or proprietary information was reviewed during the course of the inspection and if any was identified in subsequent document review that it would be properly destroyed.
On July 6, 2011, the Resident inspectors presented the inspection results to Mr. Don Grissette, Site Vice President, and other members of the licensee staff. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
4OA7 Licensee Indentified Violations
Inoperable Fire Door The following violation of very low safety significance (Green) was identified by the licensee and was a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
Facility Operating License NPF-90 for Watts Bar Nuclear Plant Unit 1, Condition 2.F, requires that TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the FPR. Contrary to the above, on April 18, 2011, the licensee found Fire Door A027 latching mechanism taped in a manner that prevented the door from automatically latching. The tape had apparently been placed there by an unknown individual during the refueling due to the inability to open the door from the auxiliary building side to the pipe chase side. The tape was removed restoring the fire door function and the latch assembly was replaced the next day. This was identified in the licensees CAP as PER 356803. This finding was of very low safety significance in accordance with IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, because the fire barrier was only moderately degraded and there were no fixed or in-situ fire ignition sources that would subject the degraded fire barrier to direct flame impingement.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- G. Boerschig, Plant Manager
- J. Bushnell, Licensing Engineer
- R. Crews, Operations Training Manager
- T. Detchemende, Emergency Preparedness Manager
- K. Dutton, Engineering Director
- D. Grissette, Site Vice President
- W. Hooks, Radiation Protection Manager
- P. Huffman, ISI Coordinator
- D. Hughes, Training Supervisor
- B. Hunt, Operations Superintendent
- D. Hutchinson, Chemistry Manager
- C. Kato, BACC Coordinator
- W. Mahan, Site Welding Engineer
- M. McFadden, Operations Manager
- J. Milner, Technical Support Superintendent, Radiation Protection
- D. Murphy, Maintenance Manager
- M. Pope, Licensing Engineer
- C. Riedl, Licensing Manager (Interim)
- A. Scales, Work Control Manager
- D. Voeller, Director, Project Management
- J. Wilcox, Security Manager
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Opened and Closed
- 05000390/2011003-01 NCV Failure to Ensure The Operability of an Emergency Battery Lighting Unit in Accordance with the Approved Fire Protection Plan (Section 1R05)
- 05000390/2011003-02 NCV Procedure AOI-30.2 C.36, Fire Safe Shutdown Room 737-A1A, Non-feasible Operator Manual Action (Section 1R05)
- 05000390/2011003-03 NCV Failure to Perform a Transient Combustible Evaluation for Storage of Oil in a Safety Related Area in Accordance with the Approved Fire Protection Plan (Section 1R05)
- 05000390/2011003-04 NCV Failure to Translate Moderate Energy Line Break Study Output into a Plant Procedure 2515/183 TI Followup to Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5)
2515/184 TI Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs) (Section 4OA5)
Closed
- 05000390/2009002-01 URI Auxiliary Feedwater System Compliance with General Design Criterion 2 (Section 1R15).
TI 2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)
Discussed
None