IR 05000382/2016001
| ML16116A210 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/25/2016 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-D |
| To: | Chisum M Entergy Operations |
| Josey J | |
| References | |
| IR 2016001 | |
| Download: ML16116A210 (42) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511 April 25, 2016 Mr. Michael Site Vice President Entergy Operations, Inc.
17265 River Road Killona, LA 70057-0751 SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3
- NRC INTEGRATED INSPECTION REPORT 05000382/2016 001
Dear Mr. Chisum:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 21, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance.
The NRC is treating these violation s as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation s or significance of the NCV s, 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 Waterford Steam Electric Station, Unit 3
. If you disagree with the cross-cutting aspect assignment 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 Waterford Steam Electric Station, Unit 3
. 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 NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jeffrey Josey , Acting Chief Projects Branch D Division of Reactor Projects Docket No.
50-382 License No
. NPF-38
Enclosure:
Inspection Report 05000382/2016-001 w/ Attachment s: 1. Supplemental Information 2. The following items are requested for the O
REGION IV Docket: 05000 382 License: NPF-38 Report: 05000 382/20 1 6 0 01 Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: January 1 through Ma r ch 3 1, 20 16 Inspectors:
F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector B. Hagar, Senior Project Engineer L. Carson, II, Senior Health Physicist N. Greene, PhD, Health Physicist Approved By:
Jeffrey Josey Acting Chief, Project s Branch D Division of Reactor Projects
- 2 -
SUMMARY
IR 05000 382/20 16001; 01/01/20 16 - 03/31/20 16; Waterford Steam Electric Station, Unit 3; Maintenance Risk Assessments and Emergent Work Control The inspection activities described in this report were performed between January 1 and March 31 , 2016 , by the resident inspectors and inspectors from the NRC's Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding 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, "Aspects within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process."
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water system work window. Specifically, the licensee failed to re-asses risk when a dry cooling tower fan in the component cooling water system was declared unavailable during the ongoing auxiliary component cooling water system work window. As a result, for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green and sending a communication to operations supervisors to re-emphasize the requirements to adequately address unavailability of plant components.
The inspectors determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configu ration. The inspectors used Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit
," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10
-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model.
The ILERP , screened out as not risk significant. In accordance with Flowchart in Appendix K, because the ICDP was less than 1x10
-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding has a procedure adherence cross-cutting aspect in the area of human performance, because individuals did not follow processes, procedures
, and work instructions. Specifically, when the additional dry cooling tower fan was declared unavailable, the licensee did not re-assess risk as soon as practical as specified in site procedures
[H.8]. (Section 1R13)
Licensee-Identified Violations
A violation of very low safety significance that wa s identified by the licensee has been reviewed by the inspectors.
Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program.
This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
PLANT STATUS
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power and remained at 100 percent power for the duration of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1 R 01 Adverse Weather Protection (71111.01)
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
On January 5, 2016, the inspectors completed an inspection of the station's readiness for seasonal extreme cold weather conditions. The inspectors reviewed the licensee's adverse weather procedures for the cold weather conditions and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of cold weather , the licensee had corrected weather-related equipment deficiencies identified during the previous cold weather season. The inspectors selected four risk-significant systems that were required to be protected from cold weather condition s: fire protection system train A fire protection system train B security diesel generator emergency diesel generator fuel oil storage The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by cold weather conditions.
The inspectors verified that operator actions described in the licensee's procedures were
adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.
These activities constitute d one sample of readiness for seasonal adverse weathe r , a s defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On January 21, 201 6, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1 R 04 Equipment Alignment (71111.04)
.1 Partial Walk
-Down
a. Inspection Scope
The inspecto rs performed partial system walk
-downs of the following risk
-significant systems: On January 21, 2016, component cooling water train A with train B out of service for maintenance On February 24, 2016, low pressure safety injection train A following maintenance On March 2, 2016, emergency feedwater train B with train A out of service for maintenance On March 22 , 2016, containment spray train A with train B out of service for maintenance The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration
. These activities constitute d four partial system walk
-down samples as defined i n Inspection Procedure 71111.04.
b. Findings
No findings were identified.
.2 Complete Walk
-Down
a. Inspection Scope
On February 3, 2016, the inspectors performed a complete system walk-down inspection of the auxiliary component cooling water system. The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in
-process design changes, temporary modifications, and other open items tracked by the licensee's operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
These activities constitute d one complete system walk
-down sample , as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1 R 05 Fire Protection (71111.05)
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety
- On January 15, 2016, fire area RAB 6, electrical penetration area On January 15, 2016, fire area RAB 32, auxiliary component cooling water room and pipe penetration area On March 5, 2016, fire area RAB 18, component cooling water heat exchanger A On March 5, 2016, fire area RAB 16, emergency diesel generator 3A On March 5, 2016, fire area ROOF E, main steam isolation valve room B For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's 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 constitute d five quarterly inspection sample s , as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1 R 11 Licensed Operator Requalification Program and Licensed Operator Performan ce (71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On March 8, 2016, the inspectors observed an evaluated simulator scenario performed by 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 during the observation
. These activities constitute completion of on e quarterly licensed operator requalification program sample , as defined in Inspection Procedure 71111.11.
b. 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 plant's main control room. At the time of the observations, the plant was in a period of heightened activity.
The inspectors observed the operators' performance of the following activities:
On February 3, 2016, control room observation during the failure of the pressurizer level control system On February 12, 2016, control room observation during a toxic chemical release in the vicinity of the plant In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure s, 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.
1 R 12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety
-related structures, systems, and components:
On February 2, 2016, emergency diesel generator room ventilation system On February 29, 2016, auxiliary component cooling water system The inspectors reviewed the extent of condition of possible common cause structure, system, and component failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constitute d completion of two maintenance effectiveness samples , a s defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
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:
On January 26, 2016, risk assessment associated with work on wet cooling tower fan 4A On January 27, 2016, risk assessment associated with work on dry cooling tower fan 12A The inspectors verified that these risk assessment 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 licensee's 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 three emergent work activities that had the potential to cause an initiating event and to affect the functional capability of mitigating systems:
On January 20, 2016, emergent work on core element assembly driv e mechanism motor generator set B On March 4, 2015, emergent work on core element drive mechanism control system On March 23, 2016, emergent yellow risk due to isolation of the essential chiller train AB 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 five maintenance risk assessments and emergent work control inspection samples , as defined in Inspection Procedure 71111.13.
b. Findings
Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities Introduction
. The inspectors identified a Green non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water (ACCW) system work window. Specifically, the licensee failed to re
-asses risk when a dry cooling tower fan in the component cooling water (CCW) system was declared unavailable during the ongoing ACCW system work window. As a result, for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions.
Description.
On January 26, 2016, the licensee was conducting planned maintenance on train A of the ACCW system. In addition to ACCW train A, other unavailable plant equipment included dry cooling tower fan 1A, the train B CCW pump, and the emergency diesel generator B2 air receiver. For this work window, the Plant Safety Index had been assessed as 9.3, which meant on
-line risk was Green.
At 8:47 a.m., dry cooling tower fan 12A started in slow speed with the control switch in the off position. The control room operators placed dry cooling tower fan 12A in fast speed to maintain its availability. At 11:58 a.m., operations personnel opened the circuit breaker for dry cooling tower fan 12A because the fan started cycling and did not consistently remain in fast speed. When the operators opened the breaker for dry cooling tower fan 12A, the fan was declared unavailable for on
-line risk purposes. Since Waterford Technical Specification 3.7.3, "Component Cooling Water and Auxiliary Component Cooling Water Systems," allows up to three dry cooling tower fans to be inoperable before entering the Limiting Condition for Operation Action Statement, operations personnel did not consider it a priority to immediately assess the impact of this additional unavailability on on
-line risk. Consequently, the site proceeded with the maintenance activities on the ACCW system as planned.
At 5:45 p.m., a risk assessment was completed and operations personnel discovered that the Plant Safety Index had changed to 7.6 when dry cooling tower fan 12A was declared unavailable. As a result, the plant's on
-line risk was Orange and had been in that condition for nearly 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. After this discovery, the licensee took actions to lower on-line risk by closing the breaker on dry cooling tower fan 12A and restoring it to available status.
The plant's on
-line risk was restored to Green at 7:45 p.m. the same day.
During their review of this issue, the inspectors noted that the licensee had not identified the inadequate timeliness with which the risk assessment was performed. Procedure E N-WM-104, "On-Line Risk Assessment," step 5.2[1](a) states that operations will perform risk assessments for emergent items, unplanned maintenance activities, or conditions impacting risk as soon as practical using quantitative and/or qualitative considerations. The inspectors also noted that this failure to adequately assess and manage risk was not recognized as a failure to meet site expectations since operations personnel were under the mindset that it was not a significant issue because this condition was allowed by plant technical specifications.
Analysis.
The inspectors determined that the licensee's failure to re
-assess and manage the increase in risk during an ACCW system work window when dry cooling tower fan 12A became unexpectedly unavailable was a performance deficiency which was reasonably within their ability to foresee and correct. The performance deficiency was more than minor, and therefore a finding, because it associated with the configuration control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configu ration. As a result, additional risk mitigating actions were not performed and activities to restore the plant to a lower risk condition were delayed.
The inspectors us ed Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit
," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10
-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model. The ILERP, screened out as not risk significant. In accordance with Flowchart 1 in Appendix K, because the ICDP was less than 1x10
-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding had a cross
-cutting aspect in the area of human performance, procedure adherence, because individuals did not follow processes, procedures and work instructions. Specifically, when dry cooling tower fan 12A was declared unavailable, the licensee did not re
-assess risk as soon as practical as specified in site procedures [H.8]
.
Enforcement.
Title 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), state s, in part, that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.
Contrary to the above, on January 26, 2016, the licensee failed to assess and manage risk that resulted from a proposed maintenance activity. Specifically, during an ACCW system maintenance work window, a dry cooling tower fan in the CCW system was emergently declared unavailable; however, the increase in risk was not adequately accounted for in a timely manner in accordance with site procedures. As a result, for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, on-line risk was maintained as Green when it should have b een elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green, and sending a communication to operations supervisors to re
-emphasize the requirements to adequately address unavailability of plant components. Because the licensee has entered the issue into their corrective action program and the finding is of very low safety significance, this violation of 10 CFR 50.65(a)(4) is being treated as an non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy
-01, "Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities.
" 1 R 15 Operability Determinations and Functionality Assessments (71111.15)
a. Inspection Scope
The inspectors reviewed five operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components
- On January 14, 2016, operability determination of the component cooling water system On February 1, 2016, operability determination of reactor coolant pump 1B On February 16, 2016, operability determination of startup channel
- 1 On February 17, 2016, functionality assessment of the fire protection system On February 25, 2016, functionality assessment of the pressurizer pressure control system The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded structure, system, or component to be operable or functional, t he inspectors verified that the licensee's 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 structures, system, or component
. These activities constitute completion of five operability and functionality review samples as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1 R 18 Plant Modifications (71111.18)
a. Inspection Scope
On January 11, 2016, the inspectors reviewed a permanent modification to the sp eed sensors associated with reactor coolant pump 2A and core protection calculator B. 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 structures, systems, or components as modified.
These activities constitute completion of one sample of permanent modifications , a s defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
1 R 19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed five post-maintenance testing activities that affected risk
-significant structures, systems, or components
- On January 13, 2016, dry cooling tower fan 8B On January 21, 2016, wet cooling tower fans train A On February 10, 2016, nitrogen accumulator
- 6 On March 10, 2016, emergency feedwater pump B On March 23, 2016, containment spray B header isolation valve CS-125B The inspectors reviewed licensing- and design-basis documents for the structures, systems, or components 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 structures, systems, or component s. These activities constitute completion of five post-maintenance testing inspection samples , as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1 R 22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed five 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 test s: On January 6, 2015, nitrogen accumulator
- 5 On February 12, 2016, auxiliary component cooling water pump B Other surveillance tests:
On January 11, 2016, review of missed surveillance for wet and dry cooling tower operability On February 25, 2016, core protection calculato r train A On March 1, 2016, containment spray pump A The inspectors verified that these test s 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 structures, systems, and component s following testing.
These activities constitute completion of five surveillance testing inspection samples , a s defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety 2 RS 1 Radiological Hazard Assessment and Exposure Controls (71124.01)
a. Inspection Scope
The inspectors assessed the licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensee's implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:
The review of plant isotopic mix and percent abundance, including hard
-to-detect radionuclides and potential alpha hazards The hazard assessment program, including a review of the licensee's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity monitoring, and surface contamination leve ls Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage and contamination controls The use of electronic dosimeters in high noise areas, dosimetry placement, implementation of EDEX, and the application of dosimetry to effectively monitor exposure for work in areas with significant dose rate gradients Controls for highly activated or contaminated materials (non
-fuel) stored within spent fuel and other storage pools Posting and physical controls for high radiation areas and very high radiation areas Radiation worker and radiation protection technician performance with respect to radiation protection work requirements Audits, self
-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of the radiological hazard assessment and exposure controls inspection, as defined in Inspection Procedure 71124.01.
b. Findings
No findings were identified.
2 RS 3 In-plant Airborne Radioactivity Control and Mitigation (71124.03)
a. Inspection Scope
The inspectors evaluated whether the licensee controlled in
-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
The licensee's use, when applicable, of installed ventilation systems as part of its engineering controls Utilization of temporary ventilation systems (e.g., high
-efficiency particulate air units) to support work in contaminated areas Airborne monitoring protocols, air quality and quantity for supplied air devices and SCBA bottles.
The licensee's respiratory protection program for use, storage, maintenance, and quality assurance of NIOSH certified equipment, qualification and training of personnel, and user performance Evaluations for the use of respirators in lieu of engineering controls to maintain occupational doses ALARA The licensee's capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training Audits, self
-assessments, and corrective action documents related to in-plant airborne radioactivity control and mitigation since the last inspection These activities constitute completion of the in
-plant airborne radioactivity control and mitigation inspection, as defined in Inspection Procedure 71124.03.
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 4OA 1 Performance Indicator Verification (71151)
.1 Unplanned Scrams per 7000
Critical Hours (IE01)
a. Inspection Scope
The inspectors reviewed licensee event reports for the period of January 1 through December 31, 2015 , to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in th ese 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 one unplanned scrams per 7000 critical hours performance indicator 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 licensee performance indicator data for the period of January 1 through December 31, 2015, 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 one unplanned power outages per 7000 critical hours performance indicator 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 licensee's basis for including or excluding in this performance indicator each scram that occurred between January 1 and December 31, 2015. 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 constitute d verification of one unplanned scrams with complications performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Occupational Exposure Control
Effectiveness (OR01)
a. Inspection Scope
The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2015 to December 31, 2015. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than
100 m Rem. 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 reported data.
These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.5 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual (ODCM) Radiological Effluent Occurrences (PR01)
a. Inspection Scope
The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between October 1, 2015 and December 31, 2015, and were reported to the NRC to verify the performance indicator data. 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 reported data.
These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA 2 Problem Identification and Resolution (71152)
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's 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 licensee's 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
On February 18, 2016, the inspectors reviewed the licensee's apparent cause evaluation entitled "Misalignment Between Problem Statements, Causes and Corrective Actions and Misclassifications of Condition Reports," for an in
-depth follow
-up. The licensee had initiated this evaluation to address several deficiencies that had been identified with the creation and disposition of condition reports.
The inspectors assessed the licensee's 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 were adequate to ensure the resolution of issues that had been previously identified with the corrective action program. In addition, the inspectors verified that condition reports were initiated in a timely manner, and were classified appropriately.
These activities constitute completion of one annual follow
-up sample as defined i n Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA 3 Follow-up of Events and Notices of Enforcement Discretion (71153)
.1 (Closed) Licensee Event Report
05000382/2015 01 , "Manual Reactor Trip due to Low Steam Generator Levels
" On June 3, 2015, at approximately 5:05 p.m., the control room operators manually tripped the reactor in anticipation of an automatic reactor trip. The inspectors' review of the reactor trip was documented in NRC Integrated Inspection Report 05000382/2015003. Following the reactor trip, off-site power train B failed to transfer from the unit auxiliary transformer to the unit startup transformers. Subsequently, emergency diesel generator B started and powered the safety
-related train B electrical buses. In reviewing the causes of the failure of the fast bus transfer, the inspectors reviewed a performance deficiency associated with the design of the alarm circuit installed for the fast bus transfer electrical components.
However, since the alarm circuit did not play a role in the failure of the fast bus transfer, the inspectors determined the performance deficiency to be minor. The previous revision of this licensee event report was included as part of this review. Th is licensee event report is closed.
.2 (Closed) Licensee Event Report 05000382/201
4-00 4-03 , "Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks
" During a plant walk-down on October 22, 2014, the inspector s identified through-wall corrosion on the emergency diesel generator fuel oil day tank vents.
The holes in these vent pipes could have allowed water to enter the day tanks and contaminate the diesel fuel oil, challenging the operability a nd functionality of both safety
-related emergency diesel generators.
The inspectors documented their findings in NRC Inspection Reports 05000382/2014007 and 05000382/2015001.
The inspectors review ed the licensee event report associated with this event and did not identify additional performance deficiencies. The previous revisions of this licensee event report were included as part of this review. This licensee event report is closed. These activities constitute completion of two event follow
-up samples, as defined in Inspection Procedure 71153. 4OA 5 Other Activities Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations.
The inspectors independently verified that the licensee's proposed interim actions would perform their intended function for flooding mitigation. Specifically:
Through a tabletop simulation with the licensee, the inspectors reviewed the sequence of licensee activities from the initial triggers that prompt them to implement their interim actions, through full implementation of those actions. The inspector s verified not only that the associated procedures clearly describe how to implement the interim actions, but also that the licensee staff has ready access to the necessary resources.
The inspectors visually examined each relevant flood
-protection feature for any indication of degradation that could prevent the feature from performing its credited function.
The inspectors walked down the associated manual actions, to verify that operators would have access to both the implementing procedures and the involved components during postulated adverse conditions.
Through these reviews, examinations, and walk
-downs, the inspectors only identified administrative issues. The inspectors verified that the licensee entered those issues into their corrective action program.
4OA 6 Meetings, Including Exit
Exit Meeting Summary
On March 24, 2016, the inspectors presented the radiation safety inspection results to Mr. R an Gilmore, General Plant Manager of Operations, 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 21, 2016, the resident inspectors presented the inspection results to Mr. Michael Chisum, 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.
4OA 7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy fo r being dispositioned as a non
-cited violation s.
Technical Specification 6.8.1, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, "Quality Assurance Program Requirements," Appendix A, Section 2.l, requires procedures for refueling and core alterations. Step 6.2.1 of Procedure OP 005, Revision 309, "RCS Drain and Fill Below RCS Hot Leg Centerline," instructs the licensee to verify, in part, that "Containment Purge is aligned for Refueling Ventilation with RAB Normal Ventilation, or adequate provisions or controls are in place to acceptably address radiological concerns." Contrary to the above, on November 18, 2015, the licensee failed to verify that Containment Purge was aligned for Refueling Ventilation with RAB Normal Ventilation or that adequate controls were in place to acceptably address radiological concerns. Specifically, the licensee proceeded with RCS fill without radiation protection monitoring for airborne radioactivity in the vicinity of the TRH hoses as required. The alignment for Refueling Ventilation was not completed because the required valve (CAP
-201), which allows alignment between containment purge and refuel ventilation, was inoperable. The licensee indicated that this condition had existed since at least Refueling Outage 18 in 2012. This finding adversely affected the Occupational Radiation Safety cornerstone because it had the potential to cause a high airborne condition local to the refuel cavity and cause unplanned exposures. The licensee's immediate corrective action was to initiate a work order to complete repairs of the inoperable CAP
-201 valve. The licensee entered this issue into their corrective action program as CR
-WF3-2015-08474. The significance of the finding was determined to be of very low safety significance (Green) because it was:
- (1) not an ALARA finding,
- (2) did not result in an overexposure,
- (3) did not involve substantial potential for an exposure, and
- (4) the ability to assess dose was not compromised. Licensee
-identified findings do not involve cross
-cutting aspects.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Chisum, Site Vice President, Operations
- R. Gilmore, Acting General Manager, Plant Operations
- D. Breaud, Radiological Effluents Specialist, Chemistry
- L. Brown, Licensing Specialist, Regulatory Assurance
- J. Cary, Supervisor, Radiation Protection
- M. Chaisson, Superintendent, Radiological Operations
- J. Clavelle, Manager, Systems
and Components
- D. Frey, Manager, Radiation Protection
- M. Haydel, Manager, Design & Program Engineering
- P. Hernandez, Supervisor, Reactor Engineering
- J. Jarrell, Director, Regulatory & Performance Improvement
- B. Lanka, Director, Engineering
- N. Lawless, Manager, Chemistry
- B. Lindsey, Senior Manager, Operations
- W. McKinney, Manager, Training
- S. Meiklejohn, Senior Licensing Specialist
- C. Miller, Supervisor, Radiation Protection
- L. Milster, Licensing Engineer, Regulatory Assurance
- N. Petit, Supervisor, Design Engineering
- P. Robinson, Supervisor, System & Component Engineering
- R. Sherman, ALARA Supervisor, Radiation Protection
- J. Signorelli, Manager, Emergency Planning
- R. Simpson, Superintendent, Operator Training
- M. Vollmer, CHP, Specialist Radiation Protection
- M. Zamber, Licensing Specialist, Regulatory Assurance
NRC Personnel
- R. Deese, Senior Reactor Analyst
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000 382-2016-001-01 NCV Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities
(Section 1R13)
Closed
-005-0 1 LER Manual Reactor Trip due to Low Steam Generator Levels (Section 4OA3.1)
- 05000382/201
4-00 4-0 3 LER Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks
(Section 4OA3.2)