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| issue date = 05/19/2014 | | issue date = 05/19/2014 | ||
| title = IR 05000498-14-002, 05000499-14-002; 01/01/2014 - 04/04/2014; South Texas Project Electric Generating Station, Units 1 and 2, Inservice Inspection Activities; Problem Identification and Resolution; Event Follow-Up | | title = IR 05000498-14-002, 05000499-14-002; 01/01/2014 - 04/04/2014; South Texas Project Electric Generating Station, Units 1 and 2, Inservice Inspection Activities; Problem Identification and Resolution; Event Follow-Up | ||
| author name = O'Keefe N | | author name = O'Keefe N | ||
| author affiliation = NRC/RGN-IV/DRP/RPB-B | | author affiliation = NRC/RGN-IV/DRP/RPB-B | ||
| addressee name = Koehl D | | addressee name = Koehl D | ||
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=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:UNITED STATES May 19, 2014 | ||
==SUBJECT:== | |||
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2014002 AND 05000499/2014002 | |||
==Dear Mr. Koehl:== | |||
On April 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the South Texas Project Electric Generating Station, Units 1 and 2, facility. On April 10, 2014, the NRC inspectors discussed the results of this inspection with Mr. G. Powell, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. | |||
The NRC inspectors documented two findings of very low safety significance (Green) in this report. Both of these findings involved violations of the NRCs requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy. | |||
If you | If you contest these violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility. | ||
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 IV, and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
Sincerely, | |||
Inspection Report 05000498/2014002 and 05000499/2014002 w/Attachment 1: Supplemental Information 2: Document Request for Occupational Radiation Safety Inspection 3: Document Request for Inservice Inspection Activities Electronic Distribution to South Texas Project | /RA/ | ||
Neil OKeefe, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 50-498, 50-499 License Nos.: NPF-76, NPF-80 Enclosure: Inspection Report 05000498/2014002 and 05000499/2014002 w/Attachment 1: Supplemental Information 2: Document Request for Occupational Radiation Safety Inspection 3: Document Request for Inservice Inspection Activities Electronic Distribution to South Texas Project | |||
=SUMMARY= | =SUMMARY= | ||
IR 05000498/2014002, 05000499/2014002; 01/01/2014 - 04/04/2014; South Texas Project | IR 05000498/2014002, 05000499/2014002; 01/01/2014 - 04/04/2014; South Texas Project | ||
Electric Generating Station, Units 1 and 2, Inservice Inspection Activities; Problem Identification and Resolution; Event Follow-Up. | |||
=== | The inspection activities described in this report were performed between January 1 and April 4, 2014, by the resident inspectors at the South Texas Project and inspectors from the NRCs Region IV office. Two findings of very low safety significance (Green) are documented in this report. These findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process. | ||
===NRC-Identified Findings and Self-Revealing Findings=== | |||
* | |||
===Cornerstone: Initiating Events=== | ===Cornerstone: Initiating Events=== | ||
: '''Green.''' | : '''Green.''' | ||
The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, | ||
Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure associated with the boric acid corrosion control program (BACCP). Specifically, | |||
Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, failed to provide adequate screening criteria for boric acid leaks. As a result, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account all the characteristics of the leak commensurate to the affected component. The licensee entered the finding into the corrective action program as Condition Report 14-5393. | |||
The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609, | |||
Appendix A, The Significance Determination Process (SDP) for Findings At-Power, | |||
Exhibit 1, the finding was determined to be of very low safety significance (Green)because the assessment of degradation did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function. The inspectors determined the finding has a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable [H.14]. (Section 1R08) | |||
===Cornerstone: Mitigating Systems=== | ===Cornerstone: Mitigating Systems=== | ||
: '''Green.''' | : '''Green.''' | ||
The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, | ||
Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure because train C essential chilled water system was rendered inoperable by failing to remove air from the system following maintenance. Specifically, the licensee failed to require a system fill and vent in Procedure 0PMP05-CH-003, York Chiller Inspection & | |||
Maintenance 300 Tons, Revision 6, following maintenance on the essential chilled water system. The condition was placed into the corrective action program as Condition Report 13-12492. The licensee has modified the essential chilled water maintenance procedure to require a full system fill and vent following maintenance. | |||
The failure to require filling and venting of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air left in the system rendered the train inoperable. Using Inspection Manual Chapter 0609, Appendix A, | |||
Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of the structure, system, and component; did not represent a loss of system or function; did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees Maintenance Rule program for greater than 24 hours. The inspectors determined that the cause of the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that this procedure was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1] (Section 4OA2.2). | |||
B. Licensee Identified None | |||
=PLANT STATUS= | |||
Unit 1 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter used to provide high-accuracy measurement of feedwater flow to the calorimetric power calculation. On January 17, 2014, Unit 1 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. On March 15, 2014, Unit 1 entered Mode 3 to begin Refueling Outage 1RE18. The unit remained shut down for the remainder of the period of inspection. | Unit 1 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter used to provide high-accuracy measurement of feedwater flow to the calorimetric power calculation. On January 17, 2014, Unit 1 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. On March 15, 2014, Unit 1 entered Mode 3 to begin Refueling Outage 1RE18. The unit remained shut down for the remainder of the period of inspection. | ||
Unit 2 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter. On January 10, 2014, Unit 2 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. The unit remained at 100 percent power for the remainder of the period of inspection. | Unit 2 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter. On January 10, 2014, Unit 2 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. The unit remained at 100 percent power for the remainder of the period of inspection. | ||
REPORT DETAILS | |||
==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== | ||
{{IP sample|IP=IP 71111.01}} | {{IP sample|IP=IP 71111.01}} | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
On January 9 and January 16, 2014, the inspectors completed an inspection of the | On January 9 and January 16, 2014, the inspectors completed an inspection of the stations readiness for extreme cold temperatures and possible ice accumulation. The inspectors reviewed the licensees adverse weather procedures for extreme cold weather conditions and evaluated the licensees implementation of these procedures. | ||
The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. The inspectors walked down the electrical components exposed to the cold weather, area heat trace circuits, and verified the sites compensatory measures were implemented. | |||
These activities constituted one sample of readiness for impending adverse weather, as defined in Inspection Procedure 71111.01. | These activities constituted one sample of readiness for impending adverse weather, as defined in Inspection Procedure 71111.01. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R04}} | ||
{{a|1R04}} | |||
==1R04 Equipment Alignment== | ==1R04 Equipment Alignment== | ||
{{IP sample|IP=IP 71111.04}} | {{IP sample|IP=IP 71111.04}} | ||
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* March 5, 2014, Unit 1, train C essential cooling water during an emergent repair of the train B essential cooling water self-cleaning discharge strainer | * March 5, 2014, Unit 1, train C essential cooling water during an emergent repair of the train B essential cooling water self-cleaning discharge strainer | ||
* April 3, 2014, Unit 1, electrical supplies for containment equipment hatch closure with reactor coolant system inventory at reactor vessel head flange level | * April 3, 2014, Unit 1, electrical supplies for containment equipment hatch closure with reactor coolant system inventory at reactor vessel head flange level | ||
* April 3, 2014, Unit 1, spent fuel pool cooling pumps while reactor fuel was located in the spent fuel pool, and an electrical power temporary modification was in place for spent fuel pool cooling pump 1A | * April 3, 2014, Unit 1, spent fuel pool cooling pumps while reactor fuel was located in the spent fuel pool, and an electrical power temporary modification was in place for spent fuel pool cooling pump 1A The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems and trains were correctly aligned for the existing plant configuration. | ||
These activities constituted seven partial system walk-down samples, as defined in Inspection Procedure 71111.04. | These activities constituted seven partial system walk-down samples, as defined in Inspection Procedure 71111.04. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R05}} | ||
{{a|1R05}} | |||
==1R05 Fire Protection== | ==1R05 Fire Protection== | ||
{{IP sample|IP=IP 71111.05}} | {{IP sample|IP=IP 71111.05}} | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors evaluated the | The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety: | ||
* January 22, 2014, Units 1 and 2, fire protection pump house, Fire Areas 59, 60, and 61 | * January 22, 2014, Units 1 and 2, fire protection pump house, Fire Areas 59, 60, and 61 | ||
* February 15, 2014, Unit 2, emergency diesel generator building, Fire Zones 504, 507, and 510 | * February 15, 2014, Unit 2, emergency diesel generator building, Fire Zones 504, 507, and 510 | ||
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* February 26, 2014, Unit 1, fuel handling building, Fire Area 35 | * February 26, 2014, Unit 1, fuel handling building, Fire Area 35 | ||
* March 4, 2014, Unit 1, mechanical auxiliary building, Fire Area 27 | * March 4, 2014, Unit 1, mechanical auxiliary building, Fire Area 27 | ||
* March 18, 2014, Unit 1, reactor containment building, Fire Area 63 | * March 18, 2014, Unit 1, reactor containment building, Fire Area 63 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions. | ||
These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05. | These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R08}} | ||
{{a|1R08}} | |||
==1R08 Inservice Inspection Activities== | ==1R08 Inservice Inspection Activities== | ||
{{IP sample|IP=IP 71111.08}} | {{IP sample|IP=IP 71111.08}} | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors directly observed the following nondestructive examinations: SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor | The inspectors directly observed the following nondestructive examinations: | ||
The inspectors reviewed records for the following nondestructive examinations: SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor | SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Elbow to pipe, 12-RC-1112-BB1, Weld 10 Ultrasonic Coolant (Record UT-2014-012) | ||
System Feedwater Feedwater Pipe Lugs, 18-FW-1030-AA1, 1PL1 Magnetic Particle System through 1PL4 (Record MT-2014-009) | |||
Component Guide support, CC-1103-HL-5006 Visual Examination Cooling (Record VTC-2012-011) (VT-3) | |||
Water System Component Guide support, CC-9103-HL-5010 Visual Examination Cooling (Record VTC-2012-012) (VT-3) | |||
Water System Reactor Penetration Nozzles (Record VE-2014-001 Bare Metal Visual (VE) | |||
Vessel & 002) | |||
Closure Head The inspectors reviewed records for the following nondestructive examinations: | |||
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Elbow to pipe, 12-RC-1112-BB1, Weld 6 Ultrasonic Coolant (Record UT-2014-020) | |||
System Reactor Elbow to pipe, 12-RC-1112-BB1, Weld 7 Ultrasonic Coolant (Record UT-2014-021) | |||
System Pressurizer Guide Support, RC-9003-HS5064 Visual Examination (Record VTC-2014-034) (VT-3) | |||
During the review and observation of each examination, the inspectors observed whether activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also reviewed the qualifications of all nondestructive examination technicians performing the inspections to determine whether they were current. | |||
The inspectors directly observed a portion of the following welding activities: | The inspectors directly observed a portion of the following welding activities: | ||
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer Pressurizer spray line pipe to RC0103 vent valve (Weld FW 0013) | SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer Pressurizer spray line pipe to RC0103 vent valve Gas Tungsten Arc (Weld FW 0013) Welding (GTAW) | ||
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer PC11 Support U-strap to PC12 Support Plate (Weld NF) | The inspectors reviewed records for the following welding activities: | ||
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer PC11 Support U-strap to PC12 Support Plate Gas Tungsten Arc (Weld NF) Welding (GTAW) | |||
The inspectors reviewed whether the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code, Section IX requirements. | |||
The inspectors also determined whether that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the results of the | The inspectors reviewed the results of the licensees bare metal visual inspection of the reactor vessel upper head penetrations to determine whether the licensee identified any evidence of boric acid challenging the structural integrity of the reactor head components and attachments. The inspectors also verified that the required inspection coverage was achieved and limitations were properly recorded. The inspectors reviewed whether the personnel performing the inspection were certified examiners to their respective nondestructive examination method. | ||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees implementation of its boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walk-down as specified in Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, and Procedure 0PGP03-ZE-0033, RCS Pressure Boundary Inspection for Boric Acid Leaks, Revision 12. The inspectors reviewed whether the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and whether engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors observed whether corrective actions taken were consistent with the ASME Code and 10 CFR Part 50, Appendix B requirements. | ||
====b. Findings==== | ====b. Findings==== | ||
=====Introduction.===== | =====Introduction.===== | ||
The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, | The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure associated with the boric acid corrosion control program (BACCP). | ||
Specifically, Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, fails to provide adequate screening criteria for boric acid leaks. | |||
=====Description.===== | =====Description.===== | ||
The inspectors reviewed Procedure 0PGP03-ZE-0133 to verify that degraded or non-conforming conditions were being properly addressed to include identification, screening, and evaluation of boric acid leaks. Section 2.18 of the procedure defines SCREENING as | The inspectors reviewed Procedure 0PGP03-ZE-0133 to verify that degraded or non-conforming conditions were being properly addressed to include identification, screening, and evaluation of boric acid leaks. Section 2.18 of the procedure defines SCREENING as Activity to determine if leakage evidence could reasonably result in degradation of component function or qualification which would necessitate a BACCP Evaluation AND to recommend a cleaning, monitoring, insulation removal and/or repair schedule. | ||
Section 4.1.3.1 states, | Section 4.1.3.1 states, The purpose of the screening is to determine if the leakage is attributable to normal plant operation or to a degraded condition, to determine if a BACCP Evaluation is required, and to recommend a cleaning, monitoring, insulation removal and/or repair schedule. This activity is performed in parallel with normal Work Control Screening processes for material conditions. Section 4.1.3.2 c. states, No qualification is required for this activity because of the rule-based, procedure-driven nature of the screening. | ||
Procedure 0PGP03-ZE-0133, Section 4.1.3.7, includes the screening criteria for determining if a leak requires an evaluation. The procedure states that if any one of the following criteria is met, then the leak does not require an evaluation: | Procedure 0PGP03-ZE-0133, Section 4.1.3.7, includes the screening criteria for determining if a leak requires an evaluation. The procedure states that if any one of the following criteria is met, then the leak does not require an evaluation: | ||
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* Leakage deposits are from Expected Leakage. | * Leakage deposits are from Expected Leakage. | ||
* Leakage deposits are dry and only on components normally at room temperature. | * Leakage deposits are dry and only on components normally at room temperature. | ||
* Leakage is Minor Leakage. The inspectors noted that the screening process is nonconservative because it is exclusive rather than inclusive, requiring only one of the boric acid leak criteria to be met to screen the leak out of an evaluation. However, failing to meet any of these conditions should require additional evaluation. Since the procedure requires no qualifications for the screening personnel, the potential exists that risk significant leaks could be inadvertently screened out. The inspectors noted that accepted industry standards, including the standard referenced by the | * Leakage is Minor Leakage. | ||
The inspectors noted that the screening process is nonconservative because it is exclusive rather than inclusive, requiring only one of the boric acid leak criteria to be met to screen the leak out of an evaluation. However, failing to meet any of these conditions should require additional evaluation. Since the procedure requires no qualifications for the screening personnel, the potential exists that risk significant leaks could be inadvertently screened out. The inspectors noted that accepted industry standards, including the standard referenced by the licensees procedure, recommend a process in which each of the defined criteria must be met to be able to screen out of an evaluation, rather than the less conservative method of meeting any one of the criteria. | |||
The inspectors reviewed a sample of condition reports documenting previously identified boric acid leaks that had screened out of an evaluation. The review identified three instances where boric acid leaks screened out of the process but the visual condition, as seen in photos of the identified condition included in the condition report, did not support the description provided. The inspectors determined the licensee had inadequately screened the following leaks: | The inspectors reviewed a sample of condition reports documenting previously identified boric acid leaks that had screened out of an evaluation. The review identified three instances where boric acid leaks screened out of the process but the visual condition, as seen in photos of the identified condition included in the condition report, did not support the description provided. The inspectors determined the licensee had inadequately screened the following leaks: | ||
* CR 12-1898 - Leakage at residential heat removal Pump 1C casing drain flange. Dry deposits confined to flange area. | * CR 12-1898 - Leakage at residential heat removal Pump 1C casing drain flange. | ||
Dry deposits confined to flange area. | |||
* CR 12-28378 - Residue buildup at the valve stem and inlet threaded connection for 1-RC-0214, reactor coolant system loop. Deposits are dry, white, and non-excessive and do not contact susceptible material. | * CR 12-28378 - Residue buildup at the valve stem and inlet threaded connection for 1-RC-0214, reactor coolant system loop. Deposits are dry, white, and non-excessive and do not contact susceptible material. | ||
* CR 13-5786 - Seat leakage past RC-0103 and RC-0163 to quick disconnect inlet. Deposits are dry, white and confined to joint. | * CR 13-5786 - Seat leakage past RC-0103 and RC-0163 to quick disconnect inlet. Deposits are dry, white and confined to joint. | ||
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The inspectors concluded that the boric acid leak documented in CR 12-1898 was not confined to the flange; the photos clearly showed the leak had moved down to a suction flange bolt of the RHR Pump 1C. Applying accepted industry standards, the inspectors determined that the leak documented in CR 12-28378 should have been classified as being excessive. Additionally, the inspectors concluded that the leak documented in CR 13-5786 was not confined to the joint, was excessive, and came into contact with a safety related carbon steel support. The inspectors discussed CR 13-5786 with the licensee and determined the leakage past values RC-0103 and RC-0163 had come into contact with a carbon steel support without being evaluated. As a result of the discussion, the licensee performed a visual examination (VT-3) of support RC 1003-HS5064 and determined that it was not degraded. | The inspectors concluded that the boric acid leak documented in CR 12-1898 was not confined to the flange; the photos clearly showed the leak had moved down to a suction flange bolt of the RHR Pump 1C. Applying accepted industry standards, the inspectors determined that the leak documented in CR 12-28378 should have been classified as being excessive. Additionally, the inspectors concluded that the leak documented in CR 13-5786 was not confined to the joint, was excessive, and came into contact with a safety related carbon steel support. The inspectors discussed CR 13-5786 with the licensee and determined the leakage past values RC-0103 and RC-0163 had come into contact with a carbon steel support without being evaluated. As a result of the discussion, the licensee performed a visual examination (VT-3) of support RC 1003-HS5064 and determined that it was not degraded. | ||
Based on these three examples, the inspectors determined that the | Based on these three examples, the inspectors determined that the licensees screening process was not consistent with the industry standards as cited by the procedure and failed to identify potentially risk significant leaks for further evaluation that impacted safety-related structures, systems, and components. | ||
=====Analysis.===== | =====Analysis.===== | ||
The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account the characteristics of the leak commensurate to the affected component, and therefore could potentially affect the structural integrity of the affected or adjacent structure, system or component. Using Inspection Manual Chapter 0609, Appendix A, | The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. | ||
Specifically, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account the characteristics of the leak commensurate to the affected component, and therefore could potentially affect the structural integrity of the affected or adjacent structure, system or component. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, the finding is determined to be of very low safety significance because the assessment of degradation did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function. The inspectors determined the finding has a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically, the screening methodology established in Procedure 0PGP03-ZE-0133 resulted in multiple potentially risk significant leaks not receiving further evaluation [H.14]. | |||
=====Enforcement.===== | =====Enforcement.===== | ||
Title 10 CFR Part 50, Appendix B, Criterion V, | Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the licensee failed to implement procedural guidance of a type appropriate to the circumstances for screening boric acid leaks, an activity affecting quality. Specifically, Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, fails to provide adequate screening criteria for boric acid leaks. Because this violation is of very low safety significance and was placed in the corrective action program as CR 14-5383, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000498/2014002-01 and 05000499/2014002-01, Failure to establish adequate screening criteria in the Boric Acid Corrosion Control Program. | ||
===.4 Steam Generator Tube Inspection Activities=== | ===.4 Steam Generator Tube Inspection Activities=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The licensee did not perform any steam generator activities during Refueling Outage 1R18. | The licensee did not perform any steam generator activities during Refueling Outage 1R18. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R11}} | ||
{{a|1R11}} | |||
==1R11 Licensed Operator Requalification Program and Licensed Operator Performance== | ==1R11 Licensed Operator Requalification Program and Licensed Operator Performance== | ||
{{IP sample|IP=IP 71111.11}} | {{IP sample|IP=IP 71111.11}} | ||
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On February 27, 2014, the inspectors observed simulator training for an operating crew. | On February 27, 2014, the inspectors observed simulator training for an operating crew. | ||
The inspectors assessed the performance of the operators and the evaluators | The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator. | ||
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11. | These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11. | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed the performance of on-shift licensed operators in the | The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to infrequently performed activities. The inspectors observed the operators performance of the following activities: | ||
* March 15, 2014, Unit 1, reactor shutdown to begin Unit 1 Refueling Outage 1RE18 | * March 15, 2014, Unit 1, reactor shutdown to begin Unit 1 Refueling Outage 1RE18 | ||
* March 17, 2014, Unit 1, reactor coolant system cooldown, pressurizer cooldown, and solid plant operations | * March 17, 2014, Unit 1, reactor coolant system cooldown, pressurizer cooldown, and solid plant operations | ||
* March 20, 2014, Unit 1, reactor coolant system drain to reduced inventory for refueling operations | * March 20, 2014, Unit 1, reactor coolant system drain to reduced inventory for refueling operations In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure and other operations department policies. | ||
These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11. | These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11. | ||
====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== | ||
{{IP sample|IP=IP 71111.13}} | {{IP sample|IP=IP 71111.13}} | ||
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The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk: | The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk: | ||
* Week of January 10, 2014, Unit 1, planned train A work week maintenance | * Week of January 10, 2014, Unit 1, planned train A work week maintenance | ||
* February 27, 2014, Unit 2, planned work week maintenance and the installation of a temporary instrument air compressor 24 | * February 27, 2014, Unit 2, planned work week maintenance and the installation of a temporary instrument air compressor 24 The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments. | ||
The inspectors also observed portions of four emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity: | |||
* January 11, 2014, Unit 1, troubleshooting of an electrical ground on the train A vital AC bus | * January 11, 2014, Unit 1, troubleshooting of an electrical ground on the train A vital AC bus | ||
* Week of February 17, 2014, Unit 2, following the failure of instrument air compressor 24 and the planned work week maintenance activities | * Week of February 17, 2014, Unit 2, following the failure of instrument air compressor 24 and the planned work week maintenance activities | ||
* March 6, 2014, Unit 2, following the failure of train A emergency diesel generator to remotely shut down due to failure of an air cylinder | * March 6, 2014, Unit 2, following the failure of train A emergency diesel generator to remotely shut down due to failure of an air cylinder | ||
* March 18, 2014, Unit 1, extended operation with the reactor coolant system in a solid water condition due to issues with not being able to lock out control rod D-6 for rapid refueling | * March 18, 2014, Unit 1, extended operation with the reactor coolant system in a solid water condition due to issues with not being able to lock out control rod D-6 for rapid refueling The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components. | ||
These activities constitute completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13. | These activities constitute completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R15}} | ||
{{a|1R15}} | |||
==1R15 Operability Determinations and Functionality Assessments== | ==1R15 Operability Determinations and Functionality Assessments== | ||
{{IP sample|IP=IP 71111.15}} | {{IP sample|IP=IP 71111.15}} | ||
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* February 19, 2014, Unit 1, operability determination of nuclear source range channel NI-31 due to startup rate output being erratic | * February 19, 2014, Unit 1, operability determination of nuclear source range channel NI-31 due to startup rate output being erratic | ||
* March 11, 2014, Unit 1, functionality assessment of train A emergency diesel generator due to failure to remotely shut down | * March 11, 2014, Unit 1, functionality assessment of train A emergency diesel generator due to failure to remotely shut down | ||
* March 19, 2014, Unit 2, operability determination of train B emergency diesel generator due to 200 dpm leak of essential cooling water to the intercooler The inspectors reviewed the timeliness and technical adequacy of the | * March 19, 2014, Unit 2, operability determination of train B emergency diesel generator due to 200 dpm leak of essential cooling water to the intercooler The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC. | ||
These activities constitute completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R18}} | ||
{{a|1R18}} | |||
==1R18 Plant Modifications== | ==1R18 Plant Modifications== | ||
{{IP sample|IP=IP 71111.18}} | {{IP sample|IP=IP 71111.18}} | ||
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On April 2, 2014, the inspectors reviewed a permanent modification to Units 1 and 2 for the post-accident sampling system to delete system requirements from Technical Specification and to develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere. | On April 2, 2014, the inspectors reviewed a permanent modification to Units 1 and 2 for the post-accident sampling system to delete system requirements from Technical Specification and to develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere. | ||
The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified. These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18. | The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified. | ||
These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R19}} | ||
{{a|1R19}} | |||
==1R19 Post-Maintenance Testing== | ==1R19 Post-Maintenance Testing== | ||
{{IP sample|IP=IP 71111.19}} | {{IP sample|IP=IP 71111.19}} | ||
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* February 5, 2014, Unit 1, essential cooling water liquid dye penetrant test following planned maintenance | * February 5, 2014, Unit 1, essential cooling water liquid dye penetrant test following planned maintenance | ||
* February 22, 2014, Unit 2, technical support center air handling system following corrective maintenance to repair the isolation damper | * February 22, 2014, Unit 2, technical support center air handling system following corrective maintenance to repair the isolation damper | ||
* March 11, 2014, Unit 2, train A emergency diesel generator following corrective maintenance to replace an air cylinder | * March 11, 2014, Unit 2, train A emergency diesel generator following corrective maintenance to replace an air cylinder The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs. | ||
These activities constitute completion of eight post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19. | These activities constitute completion of eight post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R20}} | ||
{{a|1R20}} | |||
==1R20 Refueling and Other Outage Activities== | ==1R20 Refueling and Other Outage Activities== | ||
{{IP sample|IP=IP 71111.20}} | {{IP sample|IP=IP 71111.20}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the | During the stations Refueling Outage 1RE18 that began on March 15, 2014, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following: | ||
* Review of the | * Review of the licensees outage plan prior to the outage | ||
* Monitoring of shut-down and cool-down activities | * Monitoring of shut-down and cool-down activities | ||
* Verification that the licensee maintained defense-in-depth during outage activities | * Verification that the licensee maintained defense-in-depth during outage activities | ||
* Observation and review of reduced-inventory | * Observation and review of reduced-inventory | ||
* Observation and review of fuel handling activities | * Observation and review of fuel handling activities These activities constitute completion of one refueling outage sample, as defined in Inspection Procedure 71111.20. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R22}} | ||
{{a|1R22}} | |||
==1R22 Surveillance Testing== | ==1R22 Surveillance Testing== | ||
{{IP sample|IP=IP 71111.22}} | {{IP sample|IP=IP 71111.22}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed six risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions: | The inspectors observed six risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions: | ||
In-service tests: | |||
* January 11, 2014, Unit 1, train A component cooling water pump | * January 11, 2014, Unit 1, train A component cooling water pump | ||
* March 11, 2014, Unit 2, train A emergency diesel generator | * March 11, 2014, Unit 2, train A emergency diesel generator | ||
* March 22, 2014, Unit 1, train A low head safety injection pump | * March 22, 2014, Unit 1, train A low head safety injection pump | ||
* March 22, 2014, Unit 1, train A high head safety injection pump | * March 22, 2014, Unit 1, train A high head safety injection pump | ||
* April 3, 2014, Unit 2, train D auxiliary feedwater pump | * April 3, 2014, Unit 2, train D auxiliary feedwater pump Containment isolation valve surveillance tests: | ||
* March 12, 2014, Unit 2, main steam system valve testing | * March 12, 2014, Unit 2, main steam system valve testing The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing. | ||
These activities constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22. | These activities constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22. | ||
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No findings were identified. | No findings were identified. | ||
===Cornerstone:=== | ===Cornerstone: Emergency Preparedness=== | ||
{{a|1EP6}} | {{a|1EP6}} | ||
==1EP6 Drill Evaluation== | ==1EP6 Drill Evaluation== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed an emergency preparedness drill on February 19, 2014, to verify the adequacy and capability of the | The inspectors observed an emergency preparedness drill on February 19, 2014, to verify the adequacy and capability of the licensees assessment of drill performance. | ||
The inspectors reviewed the drill scenario, observed the drill from the training simulator and the emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution. | |||
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-05. | These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-05. | ||
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==RADIATION SAFETY== | ==RADIATION SAFETY== | ||
Cornerstones: Public Radiation Safety and Occupational Radiation Safety | Cornerstones: Public Radiation Safety and Occupational Radiation Safety {{a|2RS5}} | ||
{{a|2RS5}} | |||
==2RS5 Radiation Monitoring Instrumentation== | ==2RS5 Radiation Monitoring Instrumentation== | ||
{{IP sample|IP=IP 71124.05}} | {{IP sample|IP=IP 71124.05}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors verified the accuracy and operability of the radiation monitoring equipment used by the licensee: | The inspectors verified the accuracy and operability of the radiation monitoring equipment used by the licensee: | ||
: (1) to monitor areas, materials, and workers to ensure a radiologically safe work environment; and | |||
: (2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas: | |||
* Selected plant configurations and alignments of process, post-accident, and effluent monitors with descriptions in the FSAR and the offsite dose calculation manual | * Selected plant configurations and alignments of process, post-accident, and effluent monitors with descriptions in the FSAR and the offsite dose calculation manual | ||
* Selected instrumentation, including effluent monitoring instrument; portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks | * Selected instrumentation, including effluent monitoring instrument; portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks | ||
* Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors | * Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors | ||
* Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection | * Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constitute completion of one sample of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS6}} | ||
{{a|2RS6}} | |||
==2RS6 Radioactive Gaseous and Liquid Effluent Treatment== | ==2RS6 Radioactive Gaseous and Liquid Effluent Treatment== | ||
{{IP sample|IP=IP 71124.06}} | {{IP sample|IP=IP 71124.06}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors verified that the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out of service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the | The inspectors verified that the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out of service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items: | ||
* Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection | * Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection | ||
* Effluent program implementing procedures, including sampling, monitor setpoint determinations, and dose calculations | * Effluent program implementing procedures, including sampling, monitor setpoint determinations, and dose calculations | ||
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* Meteorological dispersion and deposition factors | * Meteorological dispersion and deposition factors | ||
* Groundwater monitoring results | * Groundwater monitoring results | ||
* Changes to the | * Changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater | ||
* Identified leakage or spill events and entries made into 10 CFR 50.75 (g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term | * Identified leakage or spill events and entries made into 10 CFR 50.75 (g)records, if any, and associated evaluations of the extent of the contamination and the radiological source term | ||
* Offsite notifications and reports of events associated with spills, leaks, and groundwater monitoring results | * Offsite notifications and reports of events associated with spills, leaks, and groundwater monitoring results | ||
* Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection | * Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constitute completion of one sample of radioactive gaseous and liquid effluent treatment, as defined in Inspection Procedure 71124.06. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS7}} | ||
{{a|2RS7}} | |||
==2RS7 Radiological Environmental Monitoring Program== | ==2RS7 Radiological Environmental Monitoring Program== | ||
{{IP sample|IP=IP 71124.07}} | {{IP sample|IP=IP 71124.07}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors verified that the | The inspectors verified that the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment, and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. | ||
The inspectors verified that the radiological environmental monitoring program was implemented consistent with the | The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensees technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items: | ||
* Annual environmental monitoring reports and offsite dose calculation manual | * Annual environmental monitoring reports and offsite dose calculation manual | ||
* Selected air sampling and dosimeter monitoring stations | * Selected air sampling and dosimeter monitoring stations | ||
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* Calibration and maintenance records for selected air sample equipment and environmental sample radiation measurement instrumentation | * Calibration and maintenance records for selected air sample equipment and environmental sample radiation measurement instrumentation | ||
* Inter-laboratory comparison program results | * Inter-laboratory comparison program results | ||
* Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection | * Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|2RS8}} | {{a|2RS8}} | ||
==2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, | ==2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,== | ||
and Transportation (71124.08) | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors verified the effectiveness of the | The inspectors verified the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items: | ||
* The solid radioactive waste system description, process control program, and the scope of the | * The solid radioactive waste system description, process control program, and the scope of the licensees audit program | ||
* Control of radioactive waste storage areas, including container labeling/marking and monitoring containers for deformation or signs of waste decomposition | * Control of radioactive waste storage areas, including container labeling/marking and monitoring containers for deformation or signs of waste decomposition | ||
* Changes to the liquid and solid waste processing system configuration, including a review of waste processing equipment that is not operational or abandoned in place | * Changes to the liquid and solid waste processing system configuration, including a review of waste processing equipment that is not operational or abandoned in place | ||
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* Processes for waste classification, including use of scaling factors and 10 CFR Part 61 analysis | * Processes for waste classification, including use of scaling factors and 10 CFR Part 61 analysis | ||
* Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest | * Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest | ||
* Audits, self-assessments, reports and corrective action reports, radioactive solid waste processing and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one sample of radioactive solid waste processing and radioactive material handling, storage, and transportation, as defined in Inspection Procedure 71124.08. | * Audits, self-assessments, reports and corrective action reports, radioactive solid waste processing and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment. | ||
These activities constitute completion of one sample of radioactive solid waste processing and radioactive material handling, storage, and transportation, as defined in Inspection Procedure 71124.08. | |||
====b. Findings==== | ====b. Findings==== | ||
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==OTHER ACTIVITIES== | ==OTHER ACTIVITIES== | ||
Cornerstones: | Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security | ||
{{a|4OA1}} | {{a|4OA1}} | ||
==4OA1 Performance Indicator Verification== | ==4OA1 Performance Indicator Verification== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed licensee event reports for the period of July 2012, through December 2013, to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, | The inspectors reviewed licensee event reports for the period of July 2012, through December 2013, to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. | ||
These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed operating logs, corrective action program records, and monthly operating reports for the period of July 2012, through December 2013, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, | The inspectors reviewed operating logs, corrective action program records, and monthly operating reports for the period of July 2012, through December 2013, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. | ||
These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151. | These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151. | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees basis for including or excluding in this performance indicator each scram that occurred between July 2012, and December 2013. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. | ||
These activities constituted verification of the unplanned scrams with complications performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|4OA2}} | ||
{{a|4OA2}} | |||
==4OA2 Problem Identification and Resolution== | ==4OA2 Problem Identification and Resolution== | ||
{{IP sample|IP=IP 71152}} | {{IP sample|IP=IP 71152}} | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Throughout the inspection period, the inspectors performed daily reviews of items entered into the | Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report. | ||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors selected one issue for an in-depth follow-up: | The inspectors selected one issue for an in-depth follow-up: | ||
* On October 27, 2013, Unit 1, train C essential chilled water system expansion tank level dropped below the minimum indication upon a start of the system. The inspectors assessed the | * On October 27, 2013, Unit 1, train C essential chilled water system expansion tank level dropped below the minimum indication upon a start of the system. | ||
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions appear to be adequate to correct the condition. | |||
These activities constitute completion of one annual follow-up sample, as defined in Inspection Procedure 71152. | These activities constitute completion of one annual follow-up sample, as defined in Inspection Procedure 71152. | ||
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=====Introduction.===== | =====Introduction.===== | ||
The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, | The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure because the train C essential chilled water system was rendered inoperable by failing to remove air from the system following maintenance. Specifically, the licensee failed to incorporate a fill and vent step into their procedures after conducting maintenance on the essential chilled water system. | ||
=====Description.===== | =====Description.===== | ||
On October 27, 2013, while running essential chilled water pump 11C for nightly logs, the control room also received an essential chiller water expansion tank level LO alarm. An operator was dispatched to check the expansion tank level, but did not see any level in the sight glass. The control room operators secured the pump, and declared train C essential chilled water system inoperable and entered Technical Specification 3.7.14. | On October 27, 2013, while running essential chilled water pump 11C for nightly logs, the control room also received an essential chiller water expansion tank level LO alarm. An operator was dispatched to check the expansion tank level, but did not see any level in the sight glass. The control room operators secured the pump, and declared train C essential chilled water system inoperable and entered Technical Specification 3.7.14. | ||
The licensee did not find any signs of a leak from the system. However, when operators went to vent the system as part of their troubleshooting efforts, they found significant amounts of air being vented from multiple locations. Operators reported vent times from as long as | The licensee did not find any signs of a leak from the system. However, when operators went to vent the system as part of their troubleshooting efforts, they found significant amounts of air being vented from multiple locations. Operators reported vent times from as long as 35 seconds. The licensee conducted a fill and vent of the system and a satisfactory surveillance test before returning the system to an operable status. The licensee determined that air was introduced into the system and was trapped in a high point in the piping. When the pump was turned on, the air was swept through the system and into the expansion tank which caused the sudden drop in the expansion tank level. | ||
The | The licensees evaluation determined that this system had a history of similar issues, which sometimes caused the expansion tank to have an increased level, and operators would respond to the symptom by draining water to lower level; sometimes this later resulted in a low level on a subsequent system run. This evaluation concluded that air was being introduced through a leaking relief valve. Testing showed that the setpoint had drifted significantly lower than the required setpoint. However, the inspectors noted that this type of problem would not explain all the symptoms of the current example, and challenged the licensees conclusions. | ||
In response to the inspectors | In response to the inspectors questions, the licensee conducted a tier 2 apparent cause investigation to determine the source of the air. The licensee concluded that the lack of venting after testing the chiller unit with a hot water pack led to the introduction of air into the system. The licensee found that during major work on the system, a system venting is normally performed prior to returning the system to service. The most recent system venting for this train occurred on January 26, 2013, after a major train work week. | ||
However, for smaller scope work, | However, for smaller scope work, system venting may not be performed. On July 8, July 10, and October 3 of 2013, the licensee performed planned maintenance limited to the chiller unit. In each case, the final step was to conduct a refrigerant leak check using a hot water pack. The hot water pack is connected to the chilled water side via the drains while the isolation valves are shut. In accordance with chiller maintenance Procedure 0PMP05-CH-003, York Chiller Inspection & Maintenance 300 Tons, Revision 6, once the testing is completed, the hot water pack is disconnected and the isolation valves are opened without any local venting. On October 4, 2013, the essential chilled water system was run and tested in accordance with Procedures 0PMP05-CH-003, and 0PGP03-ZM-0025A, Post-Maintenance Testing Implementation, Revision 5. This test verified proper system acceptance criteria were met. There were no issues identified. The train C essential chilled water system was successfully run on October 25, 2013. On October 26, 2013, the control room received a chiller expansion tank HI level alarm. Operators responded and drained tank level. | ||
Revision 6, once the testing is completed, the hot water pack is disconnected and the isolation valves are opened without any local venting. On October 4, 2013, the essential chilled water system was run and tested in accordance with Procedures 0PMP05-CH-003, and 0PGP03-ZM-0025A, | |||
On October 27, | On October 27, 2013, the chiller was again run for normal rotations when surge tank levels dropped below the indicating range. The chiller was secured and the system was vented. Operators discovered a fairly long vent time which suggested an abnormal amount of air in the system. The train C essential chilled water system was declared inoperable. | ||
The inspectors concluded that this finding was appropriately categorized as being NRC-identified based on the inspectors | The inspectors concluded that this finding was appropriately categorized as being NRC-identified based on the inspectors questions driving further evaluation of the cause after the licensee had reached their initial conclusions of the cause of the problems. | ||
=====Analysis.===== | =====Analysis.===== | ||
The failure to require a fill and vent of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. | The failure to require a fill and vent of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. | ||
Specifically, air left in the essential chilled in the system following maintenance rendered the train inoperable following system venting that discovered an unexpected higher than normal volume of air in the system. Using the Inspection Manual Chapter 0609, Appendix A, Exhibit 2, | Specifically, air left in the essential chilled in the system following maintenance rendered the train inoperable following system venting that discovered an unexpected higher than normal volume of air in the system. Using the Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of the structure, system, and component; did not represent a loss of system or function; did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees Maintenance Rule program for greater than 24 hours. | ||
The inspectors determined that the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that the affected procedure was was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1]. | The inspectors determined that the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that the affected procedure was was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1]. | ||
=====Enforcement.===== | =====Enforcement.===== | ||
Title 10 CFR Part 50, Appendix B, Criterion V, | Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, maintenance Procedure 0PMP05-CH 003, York Chiller Inspection & Maintenance 300 Tons, Revision 6, used on July 8, July 10 and October 3, 2013, which directed activities affecting quality, was not appropriate to the circumstances. Specifically, Procedure 0PMP05-CH-003 did not include a step to fill and vent the essential chilled water system following maintenance. The failure to fill and vent the system resulted in the introduction of air into the system and the loss of expansion tank level indication. | ||
Revision 6, used on July 8, July 10 and October 3, 2013, which directed activities affecting quality, was not appropriate to the circumstances. Specifically, Procedure 0PMP05-CH-003 did not include a step to fill and vent the essential chilled water system following maintenance. The failure to fill and vent the system resulted in the introduction of air into the system and the loss of expansion tank level indication. | |||
This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the | This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees corrective action program as Condition Report 13-12492. (NCV 05000498/2014002-02 , Failure to Perform a Fill and Vent Results in an Inoperable Essential Chilled Water Train) | ||
{{a|4OA3}} | {{a|4OA3}} | ||
==4OA3 Follow-up of Events and Notices of Enforcement Discretion== | ==4OA3 Follow-up of Events and Notices of Enforcement Discretion== | ||
{{IP sample|IP=IP 71153}} | {{IP sample|IP=IP 71153}} | ||
===.1 (Discussed) Licensee event Report 05000498/2014-001-00: Overpower Condition Relating to the Ultrasonic Flow Measurement System In December 2013, engineering was investigating a negative trend in the correction factors for the ultrasonic flowmeter and discovered that both units had experienced feedwater pipe wall thinning that were outside the software allowances for accuracy of | ===.1 (Discussed) Licensee event Report 05000498/2014-001-00: Overpower Condition=== | ||
Relating to the Ultrasonic Flow Measurement System In December 2013, engineering was investigating a negative trend in the correction factors for the ultrasonic flowmeter and discovered that both units had experienced feedwater pipe wall thinning that were outside the software allowances for accuracy of the ultrasonic flowmeter. Power was reduced in both Unit 1 and Unit 2 to 99.6 percent power. The average feedwater pipe erosion near the ultrasonic flowmeter sensors was 60-80 mils (thousandths of an inch), compared to a nominal pipe wall thickness of 1.375 inches. In conjunction with the vendor, new transduces were fabricated, installed, and tested and both units were returned to 100 percent power. | |||
The licensees initial evaluation determined that both units were operated in excess of licensed thermal power limits (1.8 percent for Unit 1 and 1.4 percent for Unit 2) for approximated 2.5 years. The licensee further determined that Technical Specification 3.3.1 allowed outage time was exceeded. The licensee submitted Licensee Event Report 2014-001-00, Overpower Condition Relating to the Ultrasonic Flow Measurement System, on March 24, 2014. | |||
Inspectors continue to evaluate the issue, and will track this item under Licensee Event Report 2014-001-00 and any subsequent revisions to this report. The inspectors discussed the licensees ongoing evaluations to further assess the maximum power level achieved, which was expected to be lower than the initial evaluation. | |||
No findings were identified. | |||
{{a|4OA6}} | {{a|4OA6}} | ||
==4OA6 Meetings, Including Exit== | ==4OA6 Meetings, Including Exit== | ||
===Exit Meeting Summary=== | ===Exit Meeting Summary=== | ||
On February 6, 2014, the inspectors presented the radiation safety inspection results to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. | |||
On March 27, 2014, the inspectors presented the inspection results of the inservice inspection to Mr. G. Powell, Site Vice President, and other members of the licensee staff. | |||
The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. | |||
On April 10, 2014, the inspectors presented the resident inspection results to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or will be destroyed. | |||
=SUPPLEMENTAL INFORMATION= | =SUPPLEMENTAL INFORMATION= | ||
Line 506: | Line 559: | ||
===Licensee Personnel=== | ===Licensee Personnel=== | ||
: [[contact::R. Aguilera]], Manager, Health Physics | : [[contact::R. Aguilera]], Manager, Health Physics | ||
: [[contact::L. Archer]], Consulting Health Physicist, Health Physics | : [[contact::L. Archer]], Consulting Health Physicist, Health Physics | ||
: [[contact::M. Berg]], Manager, Design Engineering/Testing and Programs | : [[contact::M. Berg]], Manager, Design Engineering/Testing and Programs | ||
: [[contact::C. Bowman]], General Manager, Engineering | : [[contact::C. Bowman]], General Manager, Engineering | ||
: [[contact::W. Brost]], Engineer, Licensing | : [[contact::W. Brost]], Engineer, Licensing | ||
: [[contact::D. Bryant]], Manager, Chemistry | : [[contact::D. Bryant]], Manager, Chemistry | ||
: [[contact::R. Dunn Jr.]], Manager, Nuclear Fuel and Analysis | : [[contact::R. Dunn Jr.]], Manager, Nuclear Fuel and Analysis | ||
: [[contact::P. Estrada]], Engineer, Equipment Reliability | : [[contact::P. Estrada]], Engineer, Equipment Reliability | ||
: [[contact::T. Frahm]], Manager, Unit 2 Operations Division | : [[contact::T. Frahm]], Manager, Unit 2 Operations Division | ||
: [[contact::T. Frawley]], Manager, Strategic Business Projects | : [[contact::T. Frawley]], Manager, Strategic Business Projects | ||
: [[contact::C. Gann]], Manager, Corporate Staff Support and Owner Liaison | : [[contact::C. Gann]], Manager, Corporate Staff Support and Owner Liaison | ||
: [[contact::E. Hardcastle]], Environmental Staff, Radiological Services | : [[contact::E. Hardcastle]], Environmental Staff, Radiological Services | ||
: [[contact::J. Hartley]], Manager, Mechanical Maintenance | : [[contact::J. Hartley]], Manager, Mechanical Maintenance | ||
: [[contact::M. Hayes]], General Supervisor, Radiation Protection | : [[contact::M. Hayes]], General Supervisor, Radiation Protection | ||
: [[contact::G. Hildebrandt]], Manager, Operations | : [[contact::G. Hildebrandt]], Manager, Operations | ||
: [[contact::G. Janak]], Operations Training Manager | : [[contact::G. Janak]], Operations Training Manager | ||
: [[contact::R. Jones]], Met Lab Staff Lead Specialist, Metrology and Radiological Laboratories | : [[contact::R. Jones]], Met Lab Staff Lead Specialist, Metrology and Radiological Laboratories | ||
: [[contact::G. Kelton]], Supervisor, Radioactive Material Control | : [[contact::G. Kelton]], Supervisor, Radioactive Material Control | ||
: [[contact::D. Koehl]], President and CEO | : [[contact::D. Koehl]], President and CEO | ||
: [[contact::D. Lange]], Supervisor, I&C Maintenance | : [[contact::D. Lange]], Supervisor, I&C Maintenance | ||
: [[contact::H. Le]], Engineering Licensing Consultant | : [[contact::H. Le]], Engineering Licensing Consultant | ||
: [[contact::J. Lovejoy]], Manager, I&C Maintenance | : [[contact::J. Lovejoy]], Manager, I&C Maintenance | ||
: [[contact::F. Marroquin]], Radiation Monitoring System Engineer, Engineering | : [[contact::F. Marroquin]], Radiation Monitoring System Engineer, Engineering | ||
: [[contact::R. McNeil]], Manager, Maintenance Engineering | : [[contact::R. McNeil]], Manager, Maintenance Engineering | ||
: [[contact::M. Merritt]], Engineer, Work Control Supervisor | : [[contact::M. Merritt]], Engineer, Work Control Supervisor | ||
: [[contact::J. Milliff]], Manager, Operations Support | : [[contact::J. Milliff]], Manager, Operations Support | ||
: [[contact::J. Morris]], Acting Supervisor, Licensing | : [[contact::J. Morris]], Acting Supervisor, Licensing | ||
: [[contact::M. Murray]], Manager, Regulatory Affairs | : [[contact::M. Murray]], Manager, Regulatory Affairs | ||
: [[contact::A. Otto]], Senior Radiation Protection Technician, Health Physics | : [[contact::A. Otto]], Senior Radiation Protection Technician, Health Physics | ||
: [[contact::A. Passafuma]], Environmental Staff, Radiological Services | : [[contact::A. Passafuma]], Environmental Staff, Radiological Services | ||
: [[contact::C. Pence]], Unit Supervisor, Operations | : [[contact::C. Pence]], Unit Supervisor, Operations | ||
: [[contact::L. Peter]], Plant General Manager | : [[contact::L. Peter]], Plant General Manager | ||
: [[contact::J. Pierce]], Manager, Unit 1 Operations | : [[contact::J. Pierce]], Manager, Unit 1 Operations | ||
: [[contact::G. Powell]], Site Vice President | : [[contact::G. Powell]], Site Vice President | ||
: [[contact::C. Reddix]], Manager, Security | : [[contact::C. Reddix]], Manager, Security | ||
: [[contact::K. Reynolds]], Effluent Chemist, Chemistry | : [[contact::K. Reynolds]], Effluent Chemist, Chemistry | ||
: [[contact::R. Savage]], Engineer, Licensing Staff Specialist | : [[contact::R. Savage]], Engineer, Licensing Staff Specialist | ||
: [[contact::M. Schaefer]], Manager, Nuclear Oversight | : [[contact::M. Schaefer]], Manager, Nuclear Oversight | ||
: [[contact::M. Schoonover]], Consulting Engineer, Equipment Reliability | : [[contact::M. Schoonover]], Consulting Engineer, Equipment Reliability | ||
: [[contact::S. Shojaei]], Engineer, Repair and Replacement | : [[contact::S. Shojaei]], Engineer, Repair and Replacement | ||
: [[contact::L. Spiess]], Engineer, Inservice Inspection | : [[contact::L. Spiess]], Engineer, Inservice Inspection | ||
: [[contact::R. Stastny]], Maintenance Manager | : [[contact::R. Stastny]], Maintenance Manager | ||
: [[contact::J. Stauber]], Engineer, Inservice Inspection | : [[contact::J. Stauber]], Engineer, Inservice Inspection | ||
: [[contact::L. Sterling]], Supervisor, Licensing | : [[contact::L. Sterling]], Supervisor, Licensing | ||
: [[contact::L. Stoicescu]], Health Physicist, Radiation Protection | : [[contact::L. Stoicescu]], Health Physicist, Radiation Protection | ||
: [[contact::M. Sumrall]], Instrumentation Health Physicist | Attachment 1 | ||
: [[contact::M. Svetlik]], Consulting Engineer, Rapid Response Team | : [[contact::M. Sumrall]], Instrumentation Health Physicist | ||
: [[contact::K. Wallis]], Manager, Systems Engineering | : [[contact::M. Svetlik]], Consulting Engineer, Rapid Response Team | ||
: [[contact::D. Whiddon]], Manager, Quality Assurance | : [[contact::K. Wallis]], Manager, Systems Engineering | ||
: [[contact::P. Williams]], Boric Acid Corrosion Control | : [[contact::D. Whiddon]], Manager, Quality Assurance | ||
: [[contact::C. Younger]], Supervisor, Engineering Programs | : [[contact::P. Williams]], Boric Acid Corrosion Control | ||
: [[contact::D. Zink]], Supervising Engineering Specialist | : [[contact::C. Younger]], Supervisor, Engineering Programs | ||
: [[contact::D. Zink]], Supervising Engineering Specialist | |||
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED== | ==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED== | ||
===Opened and Closed=== | ===Opened and Closed=== | ||
: 05000498/2014002-01 | : 05000498/2014002-01 Failure to Establish Adequate Screening Criteria in the Boric NCV | ||
: 05000499/2014002-01 Acid Corrosion Control Program Failure to Perform a Fill and Vent Results in an Inoperable | |||
: | : 05000498/2014002-02 NCV Essential Chilled Water Train | ||
===Discussed=== | ===Discussed=== | ||
: 05000498/2014-001-00 LER Overpower condition relating to the Ultra Sonic Flow Measurement system | : 05000498/2014-001-00 LER Overpower condition relating to the Ultra Sonic Flow Measurement system | ||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
}} | }} |
Latest revision as of 09:54, 20 December 2019
ML14140A134 | |
Person / Time | |
---|---|
Site: | South Texas |
Issue date: | 05/19/2014 |
From: | O'Keefe N NRC/RGN-IV/DRP/RPB-B |
To: | Koehl D South Texas |
F. Sanchez | |
References | |
IR-14-002 | |
Download: ML14140A134 (59) | |
Text
UNITED STATES May 19, 2014
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2014002 AND 05000499/2014002
Dear Mr. Koehl:
On April 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the South Texas Project Electric Generating Station, Units 1 and 2, facility. On April 10, 2014, the NRC inspectors discussed the results of this inspection with Mr. G. Powell, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
The NRC inspectors documented two findings of very low safety significance (Green) in this report. Both of these findings involved violations of the NRCs requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest these violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 IV, and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Neil OKeefe, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 50-498, 50-499 License Nos.: NPF-76, NPF-80 Enclosure: Inspection Report 05000498/2014002 and 05000499/2014002 w/Attachment 1: Supplemental Information 2: Document Request for Occupational Radiation Safety Inspection 3: Document Request for Inservice Inspection Activities Electronic Distribution to South Texas Project
SUMMARY
IR 05000498/2014002, 05000499/2014002; 01/01/2014 - 04/04/2014; South Texas Project
Electric Generating Station, Units 1 and 2, Inservice Inspection Activities; Problem Identification and Resolution; Event Follow-Up.
The inspection activities described in this report were performed between January 1 and April 4, 2014, by the resident inspectors at the South Texas Project and inspectors from the NRCs Region IV office. Two findings of very low safety significance (Green) are documented in this report. These findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Initiating Events
- Green.
The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure associated with the boric acid corrosion control program (BACCP). Specifically,
Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, failed to provide adequate screening criteria for boric acid leaks. As a result, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account all the characteristics of the leak commensurate to the affected component. The licensee entered the finding into the corrective action program as Condition Report 14-5393.
The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power,
Exhibit 1, the finding was determined to be of very low safety significance (Green)because the assessment of degradation did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function. The inspectors determined the finding has a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable [H.14]. (Section 1R08)
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure because train C essential chilled water system was rendered inoperable by failing to remove air from the system following maintenance. Specifically, the licensee failed to require a system fill and vent in Procedure 0PMP05-CH-003, York Chiller Inspection &
Maintenance 300 Tons, Revision 6, following maintenance on the essential chilled water system. The condition was placed into the corrective action program as Condition Report 13-12492. The licensee has modified the essential chilled water maintenance procedure to require a full system fill and vent following maintenance.
The failure to require filling and venting of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air left in the system rendered the train inoperable. Using Inspection Manual Chapter 0609, Appendix A,
Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of the structure, system, and component; did not represent a loss of system or function; did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees Maintenance Rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that the cause of the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that this procedure was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1] (Section 4OA2.2).
B. Licensee Identified None
PLANT STATUS
Unit 1 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter used to provide high-accuracy measurement of feedwater flow to the calorimetric power calculation. On January 17, 2014, Unit 1 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. On March 15, 2014, Unit 1 entered Mode 3 to begin Refueling Outage 1RE18. The unit remained shut down for the remainder of the period of inspection.
Unit 2 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter. On January 10, 2014, Unit 2 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. The unit remained at 100 percent power for the remainder of the period of inspection.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On January 9 and January 16, 2014, the inspectors completed an inspection of the stations readiness for extreme cold temperatures and possible ice accumulation. The inspectors reviewed the licensees adverse weather procedures for extreme cold weather conditions and evaluated the licensees implementation of these procedures.
The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. The inspectors walked down the electrical components exposed to the cold weather, area heat trace circuits, and verified the sites compensatory measures were implemented.
These activities constituted one sample of readiness for impending adverse weather, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
- January 22, 2014, Units 1 and 2, fire protection system train B while the train C fire protection diesel pump was out of service for planned maintenance
- February 2, 2014, Unit 2, train B auxiliary feedwater pump while the train D turbine-driven auxiliary feedwater pump was out of service for planned maintenance
- February 15, 2014, Unit 2, train B emergency diesel generator while train A emergency diesel generator was out of service for planned maintenance
- February 26, 2014, Unit 1, train A spent fuel pool cooling pump during welding activities on train B spent fuel pool cooling system
- March 5, 2014, Unit 1, train C essential cooling water during an emergent repair of the train B essential cooling water self-cleaning discharge strainer
- April 3, 2014, Unit 1, electrical supplies for containment equipment hatch closure with reactor coolant system inventory at reactor vessel head flange level
- April 3, 2014, Unit 1, spent fuel pool cooling pumps while reactor fuel was located in the spent fuel pool, and an electrical power temporary modification was in place for spent fuel pool cooling pump 1A The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems and trains were correctly aligned for the existing plant configuration.
These activities constituted seven partial system walk-down samples, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety:
- January 22, 2014, Units 1 and 2, fire protection pump house, Fire Areas 59, 60, and 61
- February 15, 2014, Unit 2, emergency diesel generator building, Fire Zones 504, 507, and 510
- February 24, 2014, Unit 1, essential cooling water system, Fire Zones Z603, Z604, and Z605
- February 26, 2014, Unit 1, fuel handling building, Fire Area 35
- March 4, 2014, Unit 1, mechanical auxiliary building, Fire Area 27
- March 18, 2014, Unit 1, reactor containment building, Fire Area 63 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R08 Inservice Inspection Activities
The activities described in subsections 1 through 4, below, constitute completion of one inservice inspection sample, as defined in Inspection Procedure 71111.08.
.1 Nondestructive Examination (NDE) Activities and Welding Activities
a. Inspection Scope
The inspectors directly observed the following nondestructive examinations:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Elbow to pipe, 12-RC-1112-BB1, Weld 10 Ultrasonic Coolant (Record UT-2014-012)
System Feedwater Feedwater Pipe Lugs, 18-FW-1030-AA1, 1PL1 Magnetic Particle System through 1PL4 (Record MT-2014-009)
Component Guide support, CC-1103-HL-5006 Visual Examination Cooling (Record VTC-2012-011) (VT-3)
Water System Component Guide support, CC-9103-HL-5010 Visual Examination Cooling (Record VTC-2012-012) (VT-3)
Water System Reactor Penetration Nozzles (Record VE-2014-001 Bare Metal Visual (VE)
Vessel & 002)
Closure Head The inspectors reviewed records for the following nondestructive examinations:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Elbow to pipe, 12-RC-1112-BB1, Weld 6 Ultrasonic Coolant (Record UT-2014-020)
System Reactor Elbow to pipe, 12-RC-1112-BB1, Weld 7 Ultrasonic Coolant (Record UT-2014-021)
System Pressurizer Guide Support, RC-9003-HS5064 Visual Examination (Record VTC-2014-034) (VT-3)
During the review and observation of each examination, the inspectors observed whether activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also reviewed the qualifications of all nondestructive examination technicians performing the inspections to determine whether they were current.
The inspectors directly observed a portion of the following welding activities:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer Pressurizer spray line pipe to RC0103 vent valve Gas Tungsten Arc (Weld FW 0013) Welding (GTAW)
The inspectors reviewed records for the following welding activities:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer PC11 Support U-strap to PC12 Support Plate Gas Tungsten Arc (Weld NF) Welding (GTAW)
The inspectors reviewed whether the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX requirements.
The inspectors also determined whether that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications.
b. Findings
No findings were identified.
.2 Reactor Vessel Upper Head Penetration Inspection Activities
a. Inspection Scope
The inspectors reviewed the results of the licensees bare metal visual inspection of the reactor vessel upper head penetrations to determine whether the licensee identified any evidence of boric acid challenging the structural integrity of the reactor head components and attachments. The inspectors also verified that the required inspection coverage was achieved and limitations were properly recorded. The inspectors reviewed whether the personnel performing the inspection were certified examiners to their respective nondestructive examination method.
b. Findings
No findings were identified.
.3 Boric Acid Corrosion Control (BACC) Inspection Activities
a. Inspection Scope
The inspectors reviewed the licensees implementation of its boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walk-down as specified in Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, and Procedure 0PGP03-ZE-0033, RCS Pressure Boundary Inspection for Boric Acid Leaks, Revision 12. The inspectors reviewed whether the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and whether engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors observed whether corrective actions taken were consistent with the ASME Code and 10 CFR Part 50, Appendix B requirements.
b. Findings
Introduction.
The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure associated with the boric acid corrosion control program (BACCP).
Specifically, Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, fails to provide adequate screening criteria for boric acid leaks.
Description.
The inspectors reviewed Procedure 0PGP03-ZE-0133 to verify that degraded or non-conforming conditions were being properly addressed to include identification, screening, and evaluation of boric acid leaks. Section 2.18 of the procedure defines SCREENING as Activity to determine if leakage evidence could reasonably result in degradation of component function or qualification which would necessitate a BACCP Evaluation AND to recommend a cleaning, monitoring, insulation removal and/or repair schedule.
Section 4.1.3.1 states, The purpose of the screening is to determine if the leakage is attributable to normal plant operation or to a degraded condition, to determine if a BACCP Evaluation is required, and to recommend a cleaning, monitoring, insulation removal and/or repair schedule. This activity is performed in parallel with normal Work Control Screening processes for material conditions. Section 4.1.3.2 c. states, No qualification is required for this activity because of the rule-based, procedure-driven nature of the screening.
Procedure 0PGP03-ZE-0133, Section 4.1.3.7, includes the screening criteria for determining if a leak requires an evaluation. The procedure states that if any one of the following criteria is met, then the leak does not require an evaluation:
- Leakage deposit is dry with no evidence of corrosion products.
- Leakage deposits are from Expected Leakage.
- Leakage deposits are dry and only on components normally at room temperature.
- Leakage is Minor Leakage.
The inspectors noted that the screening process is nonconservative because it is exclusive rather than inclusive, requiring only one of the boric acid leak criteria to be met to screen the leak out of an evaluation. However, failing to meet any of these conditions should require additional evaluation. Since the procedure requires no qualifications for the screening personnel, the potential exists that risk significant leaks could be inadvertently screened out. The inspectors noted that accepted industry standards, including the standard referenced by the licensees procedure, recommend a process in which each of the defined criteria must be met to be able to screen out of an evaluation, rather than the less conservative method of meeting any one of the criteria.
The inspectors reviewed a sample of condition reports documenting previously identified boric acid leaks that had screened out of an evaluation. The review identified three instances where boric acid leaks screened out of the process but the visual condition, as seen in photos of the identified condition included in the condition report, did not support the description provided. The inspectors determined the licensee had inadequately screened the following leaks:
- CR 12-1898 - Leakage at residential heat removal Pump 1C casing drain flange.
Dry deposits confined to flange area.
- CR 12-28378 - Residue buildup at the valve stem and inlet threaded connection for 1-RC-0214, reactor coolant system loop. Deposits are dry, white, and non-excessive and do not contact susceptible material.
- CR 13-5786 - Seat leakage past RC-0103 and RC-0163 to quick disconnect inlet. Deposits are dry, white and confined to joint.
The inspectors concluded that the boric acid leak documented in CR 12-1898 was not confined to the flange; the photos clearly showed the leak had moved down to a suction flange bolt of the RHR Pump 1C. Applying accepted industry standards, the inspectors determined that the leak documented in CR 12-28378 should have been classified as being excessive. Additionally, the inspectors concluded that the leak documented in CR 13-5786 was not confined to the joint, was excessive, and came into contact with a safety related carbon steel support. The inspectors discussed CR 13-5786 with the licensee and determined the leakage past values RC-0103 and RC-0163 had come into contact with a carbon steel support without being evaluated. As a result of the discussion, the licensee performed a visual examination (VT-3) of support RC 1003-HS5064 and determined that it was not degraded.
Based on these three examples, the inspectors determined that the licensees screening process was not consistent with the industry standards as cited by the procedure and failed to identify potentially risk significant leaks for further evaluation that impacted safety-related structures, systems, and components.
Analysis.
The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
Specifically, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account the characteristics of the leak commensurate to the affected component, and therefore could potentially affect the structural integrity of the affected or adjacent structure, system or component. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, the finding is determined to be of very low safety significance because the assessment of degradation did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function. The inspectors determined the finding has a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically, the screening methodology established in Procedure 0PGP03-ZE-0133 resulted in multiple potentially risk significant leaks not receiving further evaluation [H.14].
Enforcement.
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the licensee failed to implement procedural guidance of a type appropriate to the circumstances for screening boric acid leaks, an activity affecting quality. Specifically, Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 7, fails to provide adequate screening criteria for boric acid leaks. Because this violation is of very low safety significance and was placed in the corrective action program as CR 14-5383, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000498/2014002-01 and 05000499/2014002-01, Failure to establish adequate screening criteria in the Boric Acid Corrosion Control Program.
.4 Steam Generator Tube Inspection Activities
a. Inspection Scope
The licensee did not perform any steam generator activities during Refueling Outage 1R18.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On February 27, 2014, the inspectors observed simulator training for an operating crew.
The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator.
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
c. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to infrequently performed activities. The inspectors observed the operators performance of the following activities:
- March 15, 2014, Unit 1, reactor shutdown to begin Unit 1 Refueling Outage 1RE18
- March 17, 2014, Unit 1, reactor coolant system cooldown, pressurizer cooldown, and solid plant operations
- March 20, 2014, Unit 1, reactor coolant system drain to reduced inventory for refueling operations In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- Week of January 10, 2014, Unit 1, planned train A work week maintenance
- February 27, 2014, Unit 2, planned work week maintenance and the installation of a temporary instrument air compressor 24 The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
The inspectors also observed portions of four emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:
- January 11, 2014, Unit 1, troubleshooting of an electrical ground on the train A vital AC bus
- Week of February 17, 2014, Unit 2, following the failure of instrument air compressor 24 and the planned work week maintenance activities
- March 6, 2014, Unit 2, following the failure of train A emergency diesel generator to remotely shut down due to failure of an air cylinder
- March 18, 2014, Unit 1, extended operation with the reactor coolant system in a solid water condition due to issues with not being able to lock out control rod D-6 for rapid refueling The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components.
These activities constitute completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed five operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
- January 20, 2014, Unit 1, operability determination of the personnel air lock due to an acrid smell and light smoke coming from an electrical relay
- February 4, 2014, Unit 1, operability determination of train C emergency diesel generator due to cooling water nitrates being in action level 2
- February 19, 2014, Unit 1, operability determination of nuclear source range channel NI-31 due to startup rate output being erratic
- March 11, 2014, Unit 1, functionality assessment of train A emergency diesel generator due to failure to remotely shut down
- March 19, 2014, Unit 2, operability determination of train B emergency diesel generator due to 200 dpm leak of essential cooling water to the intercooler The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.
These activities constitute completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed one temporary plant modification that affected risk-significant structures, systems, and components. On April 3, 2014, the inspectors reviewed a temporary modification that supplied power to the Unit 1 spent fuel pool cooling pump 1A during the train B electrical work window that removed normal power to the pump.
The inspectors verified that the licensee had installed and removed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.
These activities constitute completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
On April 2, 2014, the inspectors reviewed a permanent modification to Units 1 and 2 for the post-accident sampling system to delete system requirements from Technical Specification and to develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere.
The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified.
These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed eight post-maintenance testing activities that affected risk-significant structures, systems, or components:
- January 8, 2014, Unit 1, essential chiller 12A essential cooling water return valve EW-1002 following emergent replacement
- January 17, 2014, Unit 2, train A emergency cooling water pump traveling screen following planned replacement of screen baskets
- January 20, 2014, Unit 1, containment personnel airlock door following replacement of a relay
- January 21, 2014, Unit 1, steam generator power operated relief valve PV-7431 following planned maintenance
- January 22, 2014, Unit 2, train B emergency diesel generator fire water sprinkler deluge solenoid valve following emergent maintenance
- February 5, 2014, Unit 1, essential cooling water liquid dye penetrant test following planned maintenance
- February 22, 2014, Unit 2, technical support center air handling system following corrective maintenance to repair the isolation damper
- March 11, 2014, Unit 2, train A emergency diesel generator following corrective maintenance to replace an air cylinder The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute completion of eight post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
During the stations Refueling Outage 1RE18 that began on March 15, 2014, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:
- Review of the licensees outage plan prior to the outage
- Monitoring of shut-down and cool-down activities
- Verification that the licensee maintained defense-in-depth during outage activities
- Observation and review of reduced-inventory
- Observation and review of fuel handling activities These activities constitute completion of one refueling outage sample, as defined in Inspection Procedure 71111.20.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed six risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:
In-service tests:
- January 11, 2014, Unit 1, train A component cooling water pump
- March 11, 2014, Unit 2, train A emergency diesel generator
- March 22, 2014, Unit 1, train A low head safety injection pump
- March 22, 2014, Unit 1, train A high head safety injection pump
- April 3, 2014, Unit 2, train D auxiliary feedwater pump Containment isolation valve surveillance tests:
- March 12, 2014, Unit 2, main steam system valve testing The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on February 19, 2014, to verify the adequacy and capability of the licensees assessment of drill performance.
The inspectors reviewed the drill scenario, observed the drill from the training simulator and the emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-05.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
The inspectors verified the accuracy and operability of the radiation monitoring equipment used by the licensee:
- (1) to monitor areas, materials, and workers to ensure a radiologically safe work environment; and
- (2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
- Selected plant configurations and alignments of process, post-accident, and effluent monitors with descriptions in the FSAR and the offsite dose calculation manual
- Selected instrumentation, including effluent monitoring instrument; portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks
- Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors
- Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constitute completion of one sample of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
The inspectors verified that the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out of service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items:
- Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection
- Effluent program implementing procedures, including sampling, monitor setpoint determinations, and dose calculations
- Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews
- Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)
- Controls used to ensure representative sampling and appropriate compensatory sampling
- Effluent stack flow rates
- Part 61 analyses and methods used to determine which isotopes are included in the source term
- Meteorological dispersion and deposition factors
- Groundwater monitoring results
- Changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater
- Identified leakage or spill events and entries made into 10 CFR 50.75 (g)records, if any, and associated evaluations of the extent of the contamination and the radiological source term
- Offsite notifications and reports of events associated with spills, leaks, and groundwater monitoring results
- Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constitute completion of one sample of radioactive gaseous and liquid effluent treatment, as defined in Inspection Procedure 71124.06.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program
a. Inspection Scope
The inspectors verified that the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment, and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program.
The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensees technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items:
- Annual environmental monitoring reports and offsite dose calculation manual
- Selected air sampling and dosimeter monitoring stations
- Collection and preparation of environmental samples
- Operability, calibration, and maintenance of meteorological instruments
- Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement
- Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach groundwater
- Records required by 10 CFR 50.75(g)
- Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection
- Calibration and maintenance records for selected air sample equipment and environmental sample radiation measurement instrumentation
- Inter-laboratory comparison program results
- Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07.
b. Findings
No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
a. Inspection Scope
The inspectors verified the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:
- The solid radioactive waste system description, process control program, and the scope of the licensees audit program
- Control of radioactive waste storage areas, including container labeling/marking and monitoring containers for deformation or signs of waste decomposition
- Changes to the liquid and solid waste processing system configuration, including a review of waste processing equipment that is not operational or abandoned in place
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
- Processes for waste classification, including use of scaling factors and 10 CFR Part 61 analysis
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest
- Audits, self-assessments, reports and corrective action reports, radioactive solid waste processing and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample of radioactive solid waste processing and radioactive material handling, storage, and transportation, as defined in Inspection Procedure 71124.08.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours (IE01)
a. Inspection Scope
The inspectors reviewed licensee event reports for the period of July 2012, through December 2013, to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Unplanned Power Changes per 7000 Critical Hours (IE03)
a. Inspection Scope
The inspectors reviewed operating logs, corrective action program records, and monthly operating reports for the period of July 2012, through December 2013, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Unplanned Scrams with Complications (IE04)
a. Inspection Scope
The inspectors reviewed the licensees basis for including or excluding in this performance indicator each scram that occurred between July 2012, and December 2013. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned scrams with complications performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected one issue for an in-depth follow-up:
- On October 27, 2013, Unit 1, train C essential chilled water system expansion tank level dropped below the minimum indication upon a start of the system.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions appear to be adequate to correct the condition.
These activities constitute completion of one annual follow-up sample, as defined in Inspection Procedure 71152.
b. Findings
Introduction.
The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for an inadequate procedure because the train C essential chilled water system was rendered inoperable by failing to remove air from the system following maintenance. Specifically, the licensee failed to incorporate a fill and vent step into their procedures after conducting maintenance on the essential chilled water system.
Description.
On October 27, 2013, while running essential chilled water pump 11C for nightly logs, the control room also received an essential chiller water expansion tank level LO alarm. An operator was dispatched to check the expansion tank level, but did not see any level in the sight glass. The control room operators secured the pump, and declared train C essential chilled water system inoperable and entered Technical Specification 3.7.14.
The licensee did not find any signs of a leak from the system. However, when operators went to vent the system as part of their troubleshooting efforts, they found significant amounts of air being vented from multiple locations. Operators reported vent times from as long as 35 seconds. The licensee conducted a fill and vent of the system and a satisfactory surveillance test before returning the system to an operable status. The licensee determined that air was introduced into the system and was trapped in a high point in the piping. When the pump was turned on, the air was swept through the system and into the expansion tank which caused the sudden drop in the expansion tank level.
The licensees evaluation determined that this system had a history of similar issues, which sometimes caused the expansion tank to have an increased level, and operators would respond to the symptom by draining water to lower level; sometimes this later resulted in a low level on a subsequent system run. This evaluation concluded that air was being introduced through a leaking relief valve. Testing showed that the setpoint had drifted significantly lower than the required setpoint. However, the inspectors noted that this type of problem would not explain all the symptoms of the current example, and challenged the licensees conclusions.
In response to the inspectors questions, the licensee conducted a tier 2 apparent cause investigation to determine the source of the air. The licensee concluded that the lack of venting after testing the chiller unit with a hot water pack led to the introduction of air into the system. The licensee found that during major work on the system, a system venting is normally performed prior to returning the system to service. The most recent system venting for this train occurred on January 26, 2013, after a major train work week.
However, for smaller scope work, system venting may not be performed. On July 8, July 10, and October 3 of 2013, the licensee performed planned maintenance limited to the chiller unit. In each case, the final step was to conduct a refrigerant leak check using a hot water pack. The hot water pack is connected to the chilled water side via the drains while the isolation valves are shut. In accordance with chiller maintenance Procedure 0PMP05-CH-003, York Chiller Inspection & Maintenance 300 Tons, Revision 6, once the testing is completed, the hot water pack is disconnected and the isolation valves are opened without any local venting. On October 4, 2013, the essential chilled water system was run and tested in accordance with Procedures 0PMP05-CH-003, and 0PGP03-ZM-0025A, Post-Maintenance Testing Implementation, Revision 5. This test verified proper system acceptance criteria were met. There were no issues identified. The train C essential chilled water system was successfully run on October 25, 2013. On October 26, 2013, the control room received a chiller expansion tank HI level alarm. Operators responded and drained tank level.
On October 27, 2013, the chiller was again run for normal rotations when surge tank levels dropped below the indicating range. The chiller was secured and the system was vented. Operators discovered a fairly long vent time which suggested an abnormal amount of air in the system. The train C essential chilled water system was declared inoperable.
The inspectors concluded that this finding was appropriately categorized as being NRC-identified based on the inspectors questions driving further evaluation of the cause after the licensee had reached their initial conclusions of the cause of the problems.
Analysis.
The failure to require a fill and vent of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, air left in the essential chilled in the system following maintenance rendered the train inoperable following system venting that discovered an unexpected higher than normal volume of air in the system. Using the Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of the structure, system, and component; did not represent a loss of system or function; did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees Maintenance Rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The inspectors determined that the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that the affected procedure was was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1].
Enforcement.
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, maintenance Procedure 0PMP05-CH 003, York Chiller Inspection & Maintenance 300 Tons, Revision 6, used on July 8, July 10 and October 3, 2013, which directed activities affecting quality, was not appropriate to the circumstances. Specifically, Procedure 0PMP05-CH-003 did not include a step to fill and vent the essential chilled water system following maintenance. The failure to fill and vent the system resulted in the introduction of air into the system and the loss of expansion tank level indication.
This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees corrective action program as Condition Report 13-12492. (NCV 05000498/2014002-02 , Failure to Perform a Fill and Vent Results in an Inoperable Essential Chilled Water Train)
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Discussed) Licensee event Report 05000498/2014-001-00: Overpower Condition
Relating to the Ultrasonic Flow Measurement System In December 2013, engineering was investigating a negative trend in the correction factors for the ultrasonic flowmeter and discovered that both units had experienced feedwater pipe wall thinning that were outside the software allowances for accuracy of the ultrasonic flowmeter. Power was reduced in both Unit 1 and Unit 2 to 99.6 percent power. The average feedwater pipe erosion near the ultrasonic flowmeter sensors was 60-80 mils (thousandths of an inch), compared to a nominal pipe wall thickness of 1.375 inches. In conjunction with the vendor, new transduces were fabricated, installed, and tested and both units were returned to 100 percent power.
The licensees initial evaluation determined that both units were operated in excess of licensed thermal power limits (1.8 percent for Unit 1 and 1.4 percent for Unit 2) for approximated 2.5 years. The licensee further determined that Technical Specification 3.3.1 allowed outage time was exceeded. The licensee submitted Licensee Event Report 2014-001-00, Overpower Condition Relating to the Ultrasonic Flow Measurement System, on March 24, 2014.
Inspectors continue to evaluate the issue, and will track this item under Licensee Event Report 2014-001-00 and any subsequent revisions to this report. The inspectors discussed the licensees ongoing evaluations to further assess the maximum power level achieved, which was expected to be lower than the initial evaluation.
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On February 6, 2014, the inspectors presented the radiation safety inspection results to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On March 27, 2014, the inspectors presented the inspection results of the inservice inspection to Mr. G. Powell, Site Vice President, and other members of the licensee staff.
The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On April 10, 2014, the inspectors presented the resident inspection results to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or will be destroyed.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Aguilera, Manager, Health Physics
- L. Archer, Consulting Health Physicist, Health Physics
- M. Berg, Manager, Design Engineering/Testing and Programs
- C. Bowman, General Manager, Engineering
- W. Brost, Engineer, Licensing
- D. Bryant, Manager, Chemistry
- R. Dunn Jr., Manager, Nuclear Fuel and Analysis
- P. Estrada, Engineer, Equipment Reliability
- T. Frahm, Manager, Unit 2 Operations Division
- T. Frawley, Manager, Strategic Business Projects
- C. Gann, Manager, Corporate Staff Support and Owner Liaison
- E. Hardcastle, Environmental Staff, Radiological Services
- J. Hartley, Manager, Mechanical Maintenance
- M. Hayes, General Supervisor, Radiation Protection
- G. Hildebrandt, Manager, Operations
- G. Janak, Operations Training Manager
- G. Kelton, Supervisor, Radioactive Material Control
- H. Le, Engineering Licensing Consultant
- J. Lovejoy, Manager, I&C Maintenance
- F. Marroquin, Radiation Monitoring System Engineer, Engineering
- R. McNeil, Manager, Maintenance Engineering
- M. Merritt, Engineer, Work Control Supervisor
- J. Milliff, Manager, Operations Support
- J. Morris, Acting Supervisor, Licensing
- M. Murray, Manager, Regulatory Affairs
- A. Otto, Senior Radiation Protection Technician, Health Physics
- A. Passafuma, Environmental Staff, Radiological Services
- C. Pence, Unit Supervisor, Operations
- L. Peter, Plant General Manager
- J. Pierce, Manager, Unit 1 Operations
- G. Powell, Site Vice President
- C. Reddix, Manager, Security
- K. Reynolds, Effluent Chemist, Chemistry
- R. Savage, Engineer, Licensing Staff Specialist
- M. Schaefer, Manager, Nuclear Oversight
- M. Schoonover, Consulting Engineer, Equipment Reliability
- S. Shojaei, Engineer, Repair and Replacement
- L. Spiess, Engineer, Inservice Inspection
- R. Stastny, Maintenance Manager
- J. Stauber, Engineer, Inservice Inspection
- L. Sterling, Supervisor, Licensing
- L. Stoicescu, Health Physicist, Radiation Protection
Attachment 1
- M. Sumrall, Instrumentation Health Physicist
- M. Svetlik, Consulting Engineer, Rapid Response Team
- K. Wallis, Manager, Systems Engineering
- D. Whiddon, Manager, Quality Assurance
- P. Williams, Boric Acid Corrosion Control
- C. Younger, Supervisor, Engineering Programs
- D. Zink, Supervising Engineering Specialist
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000498/2014002-01 Failure to Establish Adequate Screening Criteria in the Boric NCV
- 05000499/2014002-01 Acid Corrosion Control Program Failure to Perform a Fill and Vent Results in an Inoperable
- 05000498/2014002-02 NCV Essential Chilled Water Train
Discussed
- 05000498/2014-001-00 LER Overpower condition relating to the Ultra Sonic Flow Measurement system