IR 05000220/2016001
| ML16134A060 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/12/2016 |
| From: | Anthony Dimitriadis Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2016001 | |
| Download: ML16134A060 (51) | |
Text
{{#Wiki_filter:May 12, 2016
SUBJECT:
NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2016001 AND 05000410/2016001
Dear Mr. Hanson:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 19, 2016, with Mr. Peter Orphanos, NMPNS Site Vice President and other members of the NMPNS staff.
NRC inspectors examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The inspectors documented three findings of very low safety significance (Green). Each of these findings involved violations of NRC requirements. Additionally, NRC inspectors documented two licensee-identified violations which were determined to be Severity Level IV in this report. 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 the NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at NMPNS. In addition, if you disagree with the cross-cutting aspect assigned to any finding, 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 I, and the NRC Resident Inspectors at NMPNS. In accordance with Title 10 of the Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access 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/ Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69 Enclosure: Inspection Report 05000220/2016001 and 05000410/2016001 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ
SUMMARY
IR 05000220/2016001 and 05000410/2016001; 01/01/2016 - 03/31/2016; Nine Mile Point
Nuclear Station, Units 1 and 2; Maintenance Risk Assessments and Emergent Work Control; Problem Identification and Resolution.
This report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified three non-cited violations (NCVs), all of which were of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red)and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of U.S.
Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, when Exelon did not assess and manage the increase in risk for online maintenance activities. Specifically on February 12, 2016, Exelon did not assess and manage risk during Unit 2 planned testing associated with the A residual heat removal (RHR) system heat exchanger (HX). The inspectors identified that although the testing would render the A RHR minimum flow valve 2RHS*MOV4A unavailable, this was not considered as part of the planned maintenance window, which resulted in an increase in risk during the unavailability of 2RHS*MOV4A. When properly calculated, plant risk should have been indicated as Yellow for the day and not
- Green.
Exelon generated issue report (IR) 02625546 to document the inspectors concern regarding the status of the availability associated with the A RHR minimum flow valve during test setup for the A RHR HX. Exelon corrective actions included evaluating the risk management activities to be implemented when the minimum flow valves are subject to maintenance or testing activities to ensure future work is properly screened.
This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelons failure to plan for the unavailability of the A RHR minimum flow valve resulted in Unit 2 being placed in an unplanned elevated risk category (i.e., Yellow) without ensuring adequate compensatory measures were established and briefed to ensure maximum availability, reliability, and capability of the system. This issue is similar to Example 7.f of IMC 0612, Appendix E, Examples of Minor Issues, because the overall elevated plant risk placed the plant into a higher licensee-established risk category. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 and IMC 0609, Significance Determination Process. For findings within the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, Attachment 4, Table 3, Paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 1, Assessment of Risk Deficit, to analyze the finding and calculated incremental core damage probability using Equipment Out Of Service (EOOS), Exelons risk assessment tool. The inspectors determined that had this condition existed for the full duration of the Technical Specification (TS) limiting condition for operation (LCO), the incremental conditional core damage probability would have been 3.46E-9. Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon did not properly implement a process of planning, controlling, and executing the work activity such that nuclear safety was the overriding priority. Specifically, Exelon did not ensure risk was properly assessed during the planning process in accordance with WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 001, prior to testing the A RHR HX, which caused unavailability of the A RHR minimum flow valve during certain periods of the test. [H.5] (Section 1R13)
- Green.
A self-revealing Green non-cited violation (NCV) of Technical Specification (TS)6.4.1, Procedures, was identified when a Unit 1 Exelon operator did not maintain proper configuration control of a plant system during a system tagout for planned maintenance. Specifically, on January 25, 2016, a Unit 1 non-licensed operator manipulated a reactor building closed-loop cooling (RBCLC) system drain valve out of sequence while performing a tagout for the #13 shutdown cooling (SDC) HX for planned maintenance. This resulted in unintentional draining of the operating RBCLC system, annunciation of multiple alarms in the main control room, and operators entering abnormal operating procedures to recover the RBCLC system. As part of corrective actions, proper configuration was promptly restored and the operator involved in the event was given a remediation plan for requalification and placed on an operations excellence plan.
This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences; and if left uncorrected, the event had potential to lead to a more significant safety concern. Specifically, the failure to quickly isolate the drain down of the RBCLC system would have required a manual reactor scram, a manual trip of all five reactor recirculation pumps (RRPs), a manual isolation of the reactor water cleanup system, a loss of cooling to the spent fuel pool (SFP) cooling system, instrument air compressors, and the control room emergency ventilation system. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency did not result in the loss of a support system, RBCLC, or affect mitigation equipment.
This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because the non-licensed operator failed to follow Exelons procedures and the instructions he received at the pre job brief stop when manipulating the drain valve.
Specifically, the non-licensed operator rationalized, without being the designated performer of the tagout, that it was acceptable to perform a valve manipulation out of sequence with the tagout plan. [H.8] (Section 4OA2)
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a Green non-cited (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for Exelons failure to take risk management actions (RMAs) as required by procedure OP-AA-108-117, Protected Equipment Program, Revision 004, during a Unit 2, Division III, emergency switchgear electrical maintenance window on January 27, 2016. Specifically contrary to procedure OP-AA-108-117, during planned maintenance, Exelon failed to post the unit coolers in the A and B RHR pump and HX rooms, the C RHR pump room, and their associated breakers as protected equipment although their inoperability would have resulted in both trains of the standby gas treatment system (SBGT) being inoperable which would require entry into Technical Specification (TS) Limiting Condition for Operation (LCO)3.0.3 and a short term shutdown action statement. Upon identification, Exelon generated IR 02617915 to document this issue. Corrective actions included creating an action item to evaluate Attachment 3 of N2-OP-52 and to determine the relevance of the TS LCO 3.0.3 entry requirement.
The inspectors determined the performance deficiency to be more than minor because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
Specifically, contrary to OP-AA-108-117, Exelon personnel failed to include the unit coolers for the Unit 2 RHR pump and HX rooms and their associated breakers, whose unavailability would have resulted in the inoperability of both trains of SBGT and necessitated entry into LCO 3.0.3. Additionally, Examples 7.e, 7.f, and 7.g from IMC 0612, Appendix E, Examples of Minor Issues, provided similar scenarios to this issue. Example 7.e details that a performance deficiency is more than minor if a failure to include accurate TS requirements in a risk assessment and if done properly, would have required RMAs, or additional RMAs under applicable plant procedures. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 to IMC 0609, Significance Determination Process. For findings within the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, Attachment 4, Table 3, Paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 2, Assessment of RMAs, to analyze the finding and calculated incremental core damage probability using EOOS, Exelons risk assessment tool, and found the result to be less than 1E-6. The inspectors determined that had this condition existed for the full duration of the TS LCO, the incremental core damage probability would have been 6.8E-7. Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon failed to follow processes, procedures and work instructions. Specifically, Exelon failed to follow procedure OP-AA-108-117, which led to the failure to protect the unit coolers for the RHR pump rooms, HX rooms, and associated breakers which could have led to a TS LCO 3.0.3 entry. [H.8] (Section 1R13)
Other Findings
Two violations of very low safety significance that were identified by Exelon were reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On March 5, 2016, operators reduced reactor power to 50 percent to perform main steam isolation valve (MSIV) partial stroke testing, control rod scram insertion timing testing, hydraulic control unit isolated stall flow and stroke time testing, and main turbine stop valve testing. Operators restored power to 100 percent the following day. On March 9, 10, and 11, operators reduced power to 85 percent for cycling RRPs on and off to facilitate maintenance on the RRPs. For each down power, operators restored reactor power to 100 percent early the following morning. Unit 1 remained at or near 100 percent for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On January 9, 2016, operators reduced reactor power to 75 percent to perform a rod pattern adjustment and to perform troubleshooting of a packing leak associated with reactor water cleanup valve 2WCS*V210.
Operators restored reactor power to 100 percent the same day. On January 30, operators reduced reactor power to 75 percent to perform a rod pattern adjustment. Operators restored reactor power to 100 percent the same day. On February 19, operators reduced reactor power to 80 percent to perform a rod pattern adjustment, control rod maintenance, and turbine valve testing. Operators restored reactor power to 100 percent on February 21. On March 10, following an unplanned isolation of feedwater heater 2FWS-E6C, operators reduced reactor power to 98 percent. Operators restored reactor power to 100 percent the following day. On March 12, operators reduced reactor power to 75 percent to perform a rod pattern adjustment and control rod friction testing. Operators restored reactor power to 100 percent the same day.
Unit 2 remained at or near 100 percent for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Exelons preparations for the onset of high winds and rain during the week of February 1, 2016. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down Unit 1 and Unit 2 switchyards; Scriba switchyard; Unit 1 emergency diesel generators (EDGs) 102 and 103; and Unit 2, Divisions I, II, and III EDGs. The inspectors verified that operator actions defined in Exelons adverse weather procedures maintained the readiness of essential systems.
The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified. ==1R04 Equipment Alignment
.1 Partial System Walkdowns
==
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
- Unit 1 emergency cooling system 11 while emergency cooling system 12 was out of service (OOS) for planned maintenance on January 7, 2016
- Unit 1 control rod drive system with potential leak-by to scram discharge volume holding tank on February 8, 2016
- Unit 1 control rod drive 11 system during planned maintenance on control rod drive 12 pump on March 14, 2016
- Unit 1 EDG 102 during unplanned maintenance associated with EDG 103 following EDG 103 failure to start on March 16, 2016
- Unit 1 liquid poison system on March 29, 2016 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed the applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TSs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to determine if system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On February 22, 2016, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 electrohydraulic control (EHC) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment lineup check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies.
Additionally, the inspectors reviewed a sample of related IRs and work orders (WOs) to ensure Exelon appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified. ==1R05 Fire Protection