IR 05000333/2009002
Download: ML091271070
Text
May 7, 2009
Mr. Peter Site Vice President Entergy Nuclear Northeast James A. FitzPatrick Nuclear Power Plant Post Office Box 110 Lycoming, NY 13093
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000333/2009002
Dear Mr. Dietrich:
On March 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed inspection report documents the inspection results which were discussed on April 9, 2009, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, two NRC identified findings of very low safety significance (Green) were identified. These findings were determined to be violations of NRC requirements. However, because of the very low safety significance, and because the violations were entered into your corrective action program, the NRC is treating these violations as non-
cited violations (NCVs) in accordance with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of the inspection report, with the basis for your denial, to the U. S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001; with a copy to the Regional Administrator, Region I; Office of Enforcement; U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at FitzPatrick. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at FitzPatrick. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Mel Gray, Chief Projects Branch 2 Division of Reactor Projects Docket No.: 50-333 License No.: DPR-59
Enclosure:
Inspection Report 05000333/2009002
w/Attachment:
Supplemental Information cc w/encl:
Senior Vice President and COO, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuclear Operations F. Murray, President and CEO, New York State Energy Research and Development Authority P. Eddy, New York State Department of Public Service P. Church, Oswego County Administrator Supervisor, Town of Scriba C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law S. Lousteau, Treasury Department, Entergy Services A. Peterson, SLO Designee, New York State Energy Research and Development Authority
SUMMARY OF FINDINGS
...........................................................................................................3
REPORT DETAILS
.......................................................................................................................5
REACTOR SAFETY
................................................................................................................5 1R01 Adverse Weather Protection .............................................................................................5 1R04 Equipment Alignment.........................................................................................................6 1R05 Fire Protection ...................................................................................................................7 1R11 Licensed Operator Requalification Program .....................................................................7 1R12 Maintenance Effectiveness ...............................................................................................8 1R13 Maintenance Risk Assessments and Emergent Work Control ..........................................8 1R15 Operability Evaluations.......................................................................................................9 1R18 Plant Modifications ..........................................................................................................10 1R19 Post-Maintenance Testing ...............................................................................................10 1R22 Surveillance Testing ........................................................................................................11 1EP6 Drill Evaluation ................................................................................................................13
RADIATION SAFETY
............................................................................................................14 2OS3 Radiation Monitoring Instrumentation and Protective Equipment...................................14
OTHER ACTIVITIES (OA)
.....................................................................................................15
4OA2 Identification and Resolution of Problems.......................................................................15 4OA3
Event Follow-up ..............................................................................................................16
4OA5 Other Activities.................................................................................................................18 4OA6
Meetings, Including Exit...................................................................................................19 ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
....................................................................................................A-1
LIST OF ITEMS
OPEN, CLOSED, AND DISCUSSED.............................................................A-1
LIST OF DOCUMENTS REVIEWED
........................................................................................A-2
LIST OF ACRONYMS
A-6
Enclosure
- OF [[]]
- FINDIN [[]]
GS
IR 05000333/2009002; 01/01/2009 - 03/31/2009; James A. FitzPatrick Nuclear Power Plant;
Surveillance Testing and Event Follow-Up.
The report covered a three-month period of inspection by resident inspectors and announced inspections by region based inspectors. One Severity Level
- IV and one Green finding associated with two non-cited violations were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (
IMC) 0609,
"Significance Determination Process" (SDP). The cross-cutting aspect for each finding was
determined using
NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in
- NUR [[]]
- A. [[]]
CFR 50.73 relative to a condition which was prohibited by Technical
Specifications (TS) 3.8.3. Specifically, on several occasions between September 2006 and July 2007 the volume for either the 'A' or 'B' fuel oil storage tanks (FOST) was such that there was an insufficient quantity of fuel oil to provide a seven day fuel oil
supply for the associated emergency diesel generator (EDG) as required per Technical
Specifications. Entergy personnel, in determining past reportability, improperly
credited the associated fuel oil day tank towards the seven day supply and erroneously concluded on September 18, 2007, that the issue was not reportable. Entergy's corrective actions included initiation of
[[::JAF-2008-04323|JAF-2008-04323]] and issuance of licensee
event report (LER) 2009-001, "Inadequate Engineering Calculation Results in
Insufficient Inventory in EDG Fuel Oil Storage Tanks." In addition, Entergy revised
applicable procedures to ensure the fuel oil storage tanks contain adequate fuel oil
inventory to remain in compliance with the
NRC and is
considered to impact the regulatory process. Such violations are dispositioned using the traditional enforcement process instead of the Significance Determination Process.
Using the Enforcement Policy Supplement I, "Reactor Operations," example D4 which states, "A failure to make a required
NRC determined this violation is more than minor and categorized as a Severity Level IV violation.
The inspectors determined that this finding had a cross-cutting aspect in the area of
problem identification and resolution related to the evaluation component because Entergy personnel did not properly consider the
- EDG [[]]
OA3)
Enclosure Cornerstone: Barrier Integrity * Green: The inspectors identified an
CFR 50, Criterion XVI, "Corrective Action," because Entergy did not identify and correct a condition adverse to quality related to a control room envelope boundary door.
Specifically, on several occasions, Entergy did not identify and implement adequate
actions to ensure a control room envelope boundary door, 70DOR-A-300-5, remained
latched and able to perform its safety function. Entergy implemented corrective
actions which included repair of the latching mechanism to improve the reliability of the door and initiated condition reports
[[::JAF-2009-01070|JAF-2009-01070]]. This finding was greater than minor because it affected the barrier integrity attribute of
structures, systems, components, and barrier performance under maintaining
radiological barrier functionality of the control room and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect operators in the control room from radionuclide releases caused by accidents or events. The finding was evaluated using
the
III because the finding represented a degradation of the
barrier function provided for the control room against toxic atmosphere and smoke as well as radiological conditions. The finding was determined to be of very low safety significance, because the amount of time the door was unlatched and ajar was limited
to 51 days and, considering the TS allowed outage time of 90 days, the maximum
potential time of 51 days represented very low safety significance considering the low
probability of a design basis accident during this time period.
The inspectors determined this finding had a cross-cutting aspect in the area of problem identification and resolution related to the identification component because
Entergy personnel did not identify the degraded condition completely and did not
recognize the impact that the degraded CRE boundary door had on the control room
envelope. (P.1(a)) (Section 1R22) B. Licensee-Identified Violations None
Enclosure
- REPORT [[]]
DETAILS Summary of Plant Status
The James A. FitzPatrick Nuclear Power Plant (FitzPatrick) began the inspection period operating
at 100 percent reactor power. On January 14, 2009, Entergy reduced reactor power to 55
percent to perform a control rod sequence exchange and to repair leaking condenser tubes and returned to 100 percent the following day. On February 18, 2009, the 'A' traveling water screen was isolated to facilitate repairs. This resulted in an increase in water velocity through the
operating traveling water screens and subsequent transport of additional debris to the
condensers. The following condenser cleaning operations were conducted to address increased
condenser differential temperature as a result of the additional debris while the 'A' traveling water screen was isolated: * On February 19, 2009, Entergy reduced reactor power to 75 percent to clean the 'B2' condenser water box and returned to 100 percent reactor power the same day; * On February 21, 2009, Entergy reduced reactor power to 75 percent to clean the 'B1' and 'B2' condenser water boxes and returned to 100 percent reactor power the following day; * On February 24, 2009, Entergy reduced reactor power to 75 percent to clean the 'B1' and 'B2' condenser water boxes and returned to 100 percent the same day; and * On February 26, 2009, Entergy reduced reactor power to 85 percent to clean the 'A1', 'B1' and 'B2' condenser water boxes and returned to 100 percent the following day.
Operators maintained the reactor at 100 percent power for the remainder of the inspection period.
1.
SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - 1 sample) a. Inspection Scope During the week beginning January 12, 2009, the site experienced severe cold weather
conditions and high winds. The inspectors reviewed the operating status of the reactor
and turbine building heating, ventilation, and air conditioning systems; reviewed the procedural limits and actions associated with cold weather; and walked down accessible areas of the reactor and turbine buildings to assess the effectiveness of the heating and ventilation systems. The inspectors reviewed the Updated Final Safety Analysis Report
(UFSAR) and performance requirements for systems selected for inspection. The
inspectors conducted discussions with operations and engineering personnel to ensure
personnel were aware of temperature restrictions and required actions. The documents reviewed are listed in the Attachment.
This activity constitutes one seasonal extreme weather condition inspection sample.
Enclosure b. Findings No findings of significance were identified. 1R04 Equipment Alignment (71111.04) .1 Quarterly Partial System Walkdown (71111.04Q - 4 samples) a. Inspection Scope
The inspectors performed four partial system walkdowns to verify the operability of
redundant or diverse trains and components during periods of system train unavailability or following periods of maintenance. The inspectors referenced the system procedures, the Updated Final Safety Analysis Report (UFSAR), and system drawings in order to verify that the alignment of the available train was proper to support its required safety functions.
The inspectors also reviewed applicable condition reports (CRs) and work orders to
ensure that Entergy personnel identified and properly addressed equipment discrepancies
that could impair the capability of the available equipment train, as required by
XVI, "Corrective Action." The documents reviewed are listed in the Attachment. The inspectors performed a partial walkdown of the following systems: * 'B' core spray pump when the 'A' core spray pump was out of service due to planned maintenance; * 'B' reactor protection system when 'A' reactor protection system was on a backup power supply due to system failure; * 'B' low pressure coolant injection system and the 'A' and 'B' core spray systems while the 'A' low pressure coolant injection system was out of service for planned maintenance; and * Reactor core isolation cooling system while the high pressure coolant injection (HPCI) system was out of service for planned maintenance.
These activities constituted four partial system walkdown inspection samples. b. Findings No findings of significance were identified. .2 Complete System Walkdown (71111.04S - 1 sample)
a. Inspection Scope The inspectors performed a complete system alignment inspection of the
- HP [[]]
CI system to identify discrepancies between the existing equipment lineup and the required lineup. During the inspection, system drawings and operating procedures were used to verify proper equipment alignment and operational status. The inspectors reviewed the open
maintenance work orders (WOs) associated with the system for deficiencies that could
affect the ability of the system to perform its function. Documentation associated with
unresolved design issues such as temporary modifications, operator workarounds and items tracked by plant engineering were also reviewed by the inspectors to assess their collective impact on system operation. In addition, the inspectors reviewed the condition
Enclosure report database to verify that equipment problems were being identified and appropriately resolved. The documents reviewed are listed in the Attachment.
These activities constituted one complete system walkdown inspection sample.
b. Findings No findings of significance were identified. 1R05 Fire Protection (71111.05) .1 Routine Resident Inspector Tours (71111.05Q - 5 samples) a. Inspection Scope
The inspectors conducted tours of fire areas to assess the material condition and
operational status of fire protection features. The inspectors verified, consistent with
applicable administrative procedures, that combustibles and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and suppression and detection equipment were appropriately maintained; and compensatory
measures for out-of-service, degraded, or inoperable fire protection equipment were
implemented in accordance with Entergy's fire protection program. The inspectors
evaluated the fire protection program against the requirements of Licensee Condition
AD-1, elevation 272 foot; * Fire Area/Zone 1A/AD-3, elevation 272 foot; * Fire Area/Zone 1A/AD-4, elevation 286 foot; * Fire Area/Zone 1A/AD-5, elevation 286 foot; and * Fire Area/Zone 1A/AD-6, elevation 300 foot. These activities constituted five quarterly fire protection inspection samples. b. Findings No findings of significance were identified. 1R11 Licensed Operator Requalification Program (71111.11) .1 Quarterly Review (71111.11Q - 1 sample) a. Inspection Scope On March 16, 2009, the inspectors observed licensed operator simulator training to
assess operator performance during scenarios to verify that operator performance was adequate and evaluators were identifying and documenting crew performance problems. The inspectors evaluated the performance of risk significant operator actions, including the use of emergency operating procedures. The inspectors assessed the clarity and
effectiveness of communications, the implementation of appropriate actions in response to
Enclosure alarms, the performance of timely control board operation and manipulation, and the oversight and direction provided by the shift manager. The inspectors also reviewed simulator fidelity to evaluate the degree of similarity to the actual control room. Licensed
operator training was evaluated for conformance with the requirements of 10 CFR Part 55, "Operators' Licenses." The documents reviewed are listed in the Attachment.
This activity constitutes one operator simulator training inspection sample. b. Findings No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12 - 2 samples)
a. Inspection Scope The inspectors reviewed performance-based problems involving selected in-scope structures, systems, or components (SSCs) to assess the effectiveness of the maintenance program. The reviews focused on the following aspects when applicable:
- Proper Maintenance Rule scoping in accordance with
- 10 CFR Part 50.65; * Characterization of reliability issues; * Changing system and component unavailability; * 10
- CFR Part 50.65 (a)(1) and (a)(2) classifications; * Identifying and addressing common cause failures; * Trending of system flow and temperature values; * Appropriateness of performance criteria for
SSCs classified (a)(1). The inspectors reviewed system health reports, maintenance backlogs, and Maintenance
Rule basis documents. The inspectors evaluated the maintenance program for
conformance with the requirements of 10 CFR Part 50.65. The documents reviewed are
listed in the Attachment. * 125 VDC power system; and * High pressure coolant injection. These activities constituted two quarterly maintenance effectiveness inspection samples.
b. Findings No findings of significance were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples) a. Inspection Scope The inspectors reviewed maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work. The inspectors
verified that risk assessments were performed as required by 10 CFR 50.65(a)(4), and
Enclosure were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The documents reviewed are listed in the Attachment.
- The week of January 5, 2009, which included high potential conditions for frazil ice, planned maintenance on the 'A' low pressure coolant injection subsystem, and surveillances involving the reactor core isolation cooling system and the 'A' residual
heat removal (RHR) system; * The week of January 12, 2009, which included 'A' average power range monitor power supply replacement, instrument surveillances that affected the reactor core isolation
cooling system, a scheduled downpower for condenser tube leak repair and high potential conditions for frazil ice; * The week of January 19, 2009, which included high potential conditions for frazil ice, planned maintenance on the
- HP [[]]
CI system, and instrument surveillances and calibrations; * The week of February 9, 2009, which included troubleshooting and repair of the 'A' reactor protection system motor-generator set, instrument surveillance tests and increased trip risk from severe weather; and * The week of February 16, 2009, which included a failure of the 'A' traveling water screen, the 'A' reactor protection system motor generator set out-of-service due to anomalies in operation and troubleshooting, and planned maintenance and
surveillances on the 'B' emergency diesel generator system, 'B' standby liquid control system, 'B' core spray system, 'B'
SW) system, and 'B' standby gas treatment system.
These activities constituted five inspection samples. b. Findings No findings of significance were identified. 1R15 Operability Evaluations (71111.15 - 4 samples) a. Inspection Scope The inspectors reviewed operability determinations to assess the acceptability of the
evaluations; when needed, the use and control of compensatory measures; and
compliance with Technical Specifications (TS). The inspectors' review included a
verification that the operability determinations were conducted as specified by
- OP -104, "Operability Determinations." The technical adequacy of the determinations was reviewed and compared to the
UFSAR, and associated design basis documents.
The documents reviewed are listed in the Attachment.
- CR -JAF-2009-00229, Initial performance test failures of the 'A' low pressure coolant injection inverter; *
[[::JAF-2009-00241|JAF-2009-00241]], Operation of the RHR system in the suppression pool cooling mode for more than 2 percent; and
Enclosure *
HOV-1 failed to open. These activities constitute four inspection samples. b. Findings No findings of significance were identified.
1R18 Plant Modifications (71111.18 - 1 sample) a. Inspection Scope
The inspectors reviewed the following plant modification to verify the design bases,
licensing bases, and performance capability of the systems were not degraded by the modification. The inspectors reviewed the modification against the requirements of 10 CFR 50.59.
The inspectors reviewed permanent plant modification EC -1630 which was implemented
to provide a
BC-9. 71BC-9 is utilized to maintain the battery charged during normal plant loads while a station battery charger is isolated. The inspectors verified that the installation was consistent with the modification documentation; that the drawings and procedures were updated as applicable; and that
the post-installation testing was adequate.
This activity constitutes one permanent plant modification inspection sample. b. Findings No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19 - 6 samples)
a. Inspection Scope The inspectors reviewed post-maintenance test procedures and associated testing
activities for selected risk-significant mitigating systems to assess whether the effect of maintenance on plant systems was adequately addressed by control room and engineering personnel. The inspectors verified that test acceptance criteria were clear,
demonstrated operational readiness, and were consistent with design basis
documentation; test instrumentation had current calibrations, adequate range, and
accuracy for the application; and tests were performed, as written, with applicable prerequisites satisfied. Upon completion, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function. Post-maintenance testing was evaluated for conformance with the requirements of 10
XI, "Test Control." The documents reviewed are listed in
the Attachment. * Work Order (WO) 00178518, troubleshoot and repair 'A' average power range monitor; *
WO 00115984, 'A' low pressure coolant injection battery and inverter preventive maintenance;
Enclosure *
- RHR [[]]
- WO [[00110513, replacement of fuel oil transfer pump 93P1-B2. This inspection constitutes six post-maintenance test samples. b. Findings No findings of significance were identified. 1R22 Surveillance Testing (71111.22 - 6 samples) a. Inspection Scope The inspectors witnessed performance of surveillance tests (]]
Technical Requirements Manual, and Entergy procedure requirements. The inspectors
verified that test acceptance criteria were clear, demonstrated operational readiness, and
were consistent with design basis documents; test instrumentation had current
calibrations, adequate range, and accuracy for the application; and tests were performed, as written, with applicable prerequisites satisfied. Upon ST completion, the inspectors verified that equipment was returned to the status specified to perform its safety function.
The documents reviewed are listed in the Attachment. The following STs were reviewed:
- ST -15G, "Pressure Suppression Chamber - Reactor Building Vacuum Breaker Operability and Setpoint Test (
IST)," Revision 21. These activities represented six surveillance testing inspection samples.
b. Findings
Introduction: The inspectors identified an
- XVI , "Corrective Action," because Entergy did not identify and correct a condition adverse to quality related to a control room envelope (
CRE) boundary door.
Specifically, Entergy did not identify and implement adequate actions to ensure the safety-
related
DOR-A-300-5, remained latched and able to perform its
safety function. Description: Following the performance of
BB, "CREVAS B Operability Test," on March 19, 2009, the inspectors walked down areas involved during the surveillance test
approximately four hours after completion to ensure all equipment had been restored to an
operable condition. The inspectors identified door
- HV [[]]
AC room, to be unlatched
Enclosure and slightly ajar. After discovering the door unlatched and ajar, the inspectors verified no Entergy personnel
were in the two rooms associated with door 70DOR-A-300-5, closed and latched the door,
and notified the control room personnel of the deficiency. Entergy personnel verified the
door's condition, initiated condition report
JAF-2009-001021, and initiated an
engineering request to consider installing alarm capability to monitor the condition of the door. In addition, Entergy had previously identified the door to be unlatched on January 31, 2009 and initiated
[[::JAF-2009-00387|JAF-2009-00387]] on
February 6, 2009, considering its purpose to be sufficient for trending purposes only. The
inspectors concluded it would have been reasonable to investigate the latch mechanism
condition at that time. On March 23, 2009, the inspectors identified door 70DOR-A-300-5 unlatched a third time
and the door handle latch mechanism to be loose. Entergy continued to emphasize to
personnel the importance of ensuring the door latched and attempted to tighten the
mechanism. On March 24, 2009, the inspectors identified door 70DOR-A-300-5 unlatched a fourth time
and also identified that the latch mechanism was still loose. In addition, the inspectors
identified that the latch became unlatched when the door was flexed a small amount. This
flexing would occur with changes in the differential pressure across the door, which is a
common event. Entergy initiated
[[::JAF-2009-01070|JAF-2009-01070]] and performed repairs and enhancements to the latching mechanism to improve the reliability of the door.
In order for the
CRE boundary must
be maintained such that the CRE occupant dose from a large radioactive release does not
exceed the calculated dose in the licensing basis consequence analyses for design basis accidents, and that
DOR-A-300-5 must be closed and latched in order to maintain these conditions.
Although procedure AP-19.18, "Control Room Envelope Habitability Program," revision 0,
allows intermittent opening of the CRE boundary under administrative controls, as
permitted by a note included in TS 3.7.3, the door's condition in this case was not
controlled and its state was unknown and unreliable. Entergy's corrective actions included repair and enhancements to the latching mechanism
to improve the reliability of the door, initiating condition reports
[[::JAF-2009-01070|JAF-2009-01070]], and initiating an engineering request to consider installing alarm
capability when the door is not maintained closed and latched. Analysis: There was an
- NRC -identified performance deficiency in that Entergy did not promptly identify and correct a condition adverse to quality associated with the
boundary door. This finding is greater than minor because it affected the barrier integrity
attribute of structures, systems, components, and barrier performance under maintaining
radiological barrier functionality of the control room and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.
The finding was evaluated using
SDP)
Enclosure Phase I and screened to a
III review because the finding represented a degradation of the barrier function provided for the control room against toxic atmosphere and smoke as well as radiological conditions. The finding was determined to be of very
low safety significance (Green) because the amount of time the door was unlatched and
ajar was limited to 51 days. The mitigating actions immediately required by action
statement
CRE occupant
exposures to radiological, chemical, and smoke hazards will not exceed limits. In addition, action
CRE boundary to operable status has a required completion time of 90 days. Therefore, considering the allowed outage time of 90 days, the maximum
potential time of 51 days represents very low safety significance considering the low
probability of a design basis accident during this time period. The inspectors determined that this finding had a cross-cutting aspect in the area of problem identification and resolution within the identification component because Entergy
personnel did not identify the degraded condition completely and therefore did not
recognize the impact that the degraded CRE boundary door had on the control room
envelope. (P.1(a)) Enforcement:
XVI, "Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality, such as
failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-
conformances are promptly identified and corrected. Contrary to the above, between January 31 and March 24, 2009, Entergy did not implement measures to promptly identify and correct a condition adverse to quality associated with a
CRE boundary door was
inoperable. Entergy took corrective actions to repair the latching mechanism to improve
the reliability of the door. Because this violation was of very low safety significance, was
not repetitive or willful, and it was entered into Entergy's corrective action program, this violation is being treated as an
NCV 05000333/2009002-01: Inoperable Control Room Envelope Door.) Cornerstones: Emergency Preparedness 1EP6 Drill Evaluation (71114.06 - 1 sample) a. Inspection Scope
The inspectors observed emergency response organization activities during the emergency preparedness drill that was conducted on February 11, 2009. The inspectors verified that emergency classification declarations, notifications, and protective action recommendations were properly completed. The inspectors evaluated the drill for
conformance with the requirements of 10 CFR 50, Appendix E, "Emergency Planning and
Preparedness for Production and Utilization Facilities." The inspectors observed Entergy's
critique and compared Entergy's self-identified issues with observations from the inspectors' review to ensure that performance issues were properly identified.
This activity constitutes one drill evaluation inspection sample.
Enclosure b. Findings No findings of significance were identified. 2.
- RADIAT [[]]
- ION [[]]
OS3 Radiation Monitoring Instrumentation and Protective Equipment a. Inspection Scope (71121.03 - 9 samples) During January 26-29, 2009, the inspectors conducted the following activities to evaluate
the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program for issuing self-contained breathing apparatus (SCBA) to emergency response personnel. Implementation of these programs was reviewed
against the criteria contained in 10 CFR 20, applicable industry standards, and the
licensee's procedures. 1. Updated final safety analysis report (UFSAR) describing the liquid radwaste system, solid radwaste system, and gaseous radwaste system were reviewed by the inspections to identify applicable radiation monitors associated with transient high
radiation areas in the plant. 2. The inspectors identified and reviewed documentation for various radiation detection instruments used at the licensee's facility. The radiation protection (RP) instrument issue area provided for the selection of portable RP instruments that were available for
use for job coverage of radiologically significant areas. 3. Current calibration records, functional check records, and applicable calibration procedures were reviewed by the inspectors for the following plant radiation monitors and portable RP instruments. In addition, the applicable calibrators utilized were
reviewed for appropriate instrument calibration geometries and National Institute for
Science and Technology (NIST) standard traceability. Plant Radiation Monitors Main steam line radiation monitors (17RM-251A/B/C/D) Transverse in-core probe (TIP) room area radiation monitors (18RM-21-23/24)
Refuel floor area radiation monitors (18RM-021-12/13/14/30)
Containment radiation monitors (27RM-104A/B)
Steam Jet Air Ejector (SJAE) gas monitors (17RM-150A/B) RP Instruments Electronic dosimeters
Radiation survey instruments
Extendable probe survey instruments
Neutron radiation survey instruments Continuous air monitors Air samplers
Personal lapel air sampler
Enclosure Beta and Alpha sample counters Personnel Contamination Monitors (PM7,
IPM8) Small Article Monitors (SAM)
Calibrators 2 Shepherd 89 survey instrument calibrators (RP Instrument Calibration Lab)
Shepherd 142-10 panoramic calibrator (Radwaste Building, 298' elevation) 4. The inspectors reviewed radiological incidents involving internal exposures identified by condition reports for 2008. In addition, dosimetry electronic records were queried
for any internal exposures >50 mrem committed effective dose equivalent. None were identified for further review. 5. Condition reports were reviewed (See Section 4OA2), with respect to radiation protection program deficiencies to determine if the deficiencies were appropriately
characterized and corrected commensurate with their safety significance. 6. Based on the condition reports reviewed (See Section
RP portable instruments listed in 3) above, the instrument's calibration expiration and response checks were reviewed. The applicable response
check beta-source and instrument sign-out procedures were also reviewed. The inspectors queried radiation protection technicians regarding appropriate instrument selection and observed self verification of instrument operability prior to use. 8. Emergency plan-specified self contained breathing apparatus (SCBA) equipment and qualified users were sampled based on Fitzpatrick Emergency Plan documents, this included inspection of selected
- SCBA s (Control Room, Operations Support Center, Security), air bottle cascade systems, the Bauer Breathing Air Compressor (39
AC-8),
and the Service Air Compressors (39AC-2A/2B/2C).
- SC [[]]
BA qualification records for all
on-shift reactor operators were verified for currency and that required spectacles were
stored nearby and readily available. The inspectors also verified that air used to fill the
- SCBA s met the Grade D quality criteria of the Compressed Gas Association. 9. The inspectors examined selected
SCBA units in the main control room, security building and operations support center for periodic air cylinder hydrostatic testing and
maintenance records. Review of approved replacement parts documentation and
certification of the repair personnel was performed. b. Findings
No findings of significance were identified.
4.
- OTHER [[]]
ACTIVITIES (OA) 4OA2 Identification and Resolution of Problems (71152)
Enclosure .1 Review of Items Entered into the Corrective Action Program a. Inspection Scope As required by Inspection Procedure 71152, "Identification and Resolution of Problems," to
identify repetitive equipment failures or specific human performance issues for follow-up,
the inspectors performed a daily screening of all items entered into Entergy's corrective action program. The review was accomplished by accessing Entergy's computerized database for
CR screening meetings. In accordance with the baseline inspection procedures, the inspectors selected items
across the initiating events, mitigating systems, and barrier integrity cornerstones for additional follow-up and review. The inspectors assessed Entergy's threshold for problem identification, the adequacy of the cause analyses, and extent of condition review,
operability determinations, and the timeliness of the specified corrective actions. The CRs
reviewed are listed in the Attachment.
b. Assessment and Observations No findings of significance were identified. The inspectors determined that Entergy staff
appropriately identified equipment, human performance and program issues at an
appropriate threshold and entered them into the corrective action program. .2 Annual Sample: Operator Workaround Program (71152 - 1 sample)
a. Inspection Scope The inspectors reviewed the cumulative effects of operator workaround conditions on the reliability, availability, potential for mis-operation of a system, and on the operators' ability to implement abnormal or emergency operating procedures. The inspectors reviewed the
results of Entergy surveillance test ST-99H, "Operations Cumulative Impact Assessment,"
and the resolution of items identified in the assessment. The inspectors reviewed
Entergy's program for identifying operator workaround conditions at an appropriate
threshold and for entering them into the corrective action program. In addition, the inspectors reviewed operating department records including standing orders for operational decision-making issues and operability evaluations.
This activity constitutes one inspection sample. b. Assessment and Observations No findings of significance were identified. The inspectors determined that Entergy's
corrective action program was effectively used to identify and resolve operator workaround
conditions.
LER) 05000333/2009001-00, Inadequate Engineering Calculation Results in Insufficient Inventory in EDG Fuel Oil Storage Tanks
Enclosure Introduction: The inspectors identified a Severity Level
CFR 50.73 relative to a condition which was prohibited by Technical Specifications (TS)
3.8.3. Specifically, on several occasions between September 2006 and July 2007 the
volume for the 'A' or 'B' fuel oil storage tanks (FOST) was such that there was an
insufficient quantity of fuel oil to provide a seven day fuel oil supply for the associated
emergency diesel generator as required per
TS allowed a range of energy (or "heat") content of the fuel oil as represented by American Petroleum
Institute (API) gravity from 27 degrees to 39 degrees, which would result in the TSs
specified minimum volume of 32,000 gallons to be insufficient for seven days continuous operation of the emergency diesel generators without resupply from an external source. Entergy initiated
[[::JAF-2007-02392|JAF-2007-02392]] in order to evaluate and correct the condition and
evaluate the issue for reportability based upon actual past
NRC determined that Entergy staff did not properly identify and evaluate the potential for
vortexing in the
- EDG [[]]
FOST inventory calculation did not include any allowance for suction line
submergence to prevent air entrainment resulting from the effects of vortexing. Entergy
personnel initiated
- JAF -2007-02490 in order to evaluate and correct the condition and evaluate the issue for reportability in combination with
- JAF -2007-02392 due to the cumulative effect of the two issues. Although Entergy maintains the quantity of oil in the
- FO [[]]
STs at greater than the minimum
required by
- TS for both volume and heat content, the inspectors determined that there were, at a minimum, four occasions between September 17, 2006 and July 6, 2007 in which a condition prohibited by
- FO [[]]
ST did not have a sufficient
quantity of fuel oil to support seven days of operation for a duration greater than 16 days
(the duration allowed by TSs prior to requiring actions to begin shutdown of the plant).
Specifically, the 'A'
- FO [[]]
ST did not have a sufficient capacity at least three times for
durations of 19, 51, and 21 days, and the 'B'
- FO [[]]
ST did not have a sufficient quantity at least once for 19 days. The inspectors determined that Entergy staff improperly credited the fuel oil stored within
the day tank (crediting a volume of fuel oil up to 525 gallons) in order to conclude that
there had not been a time when seven days of fuel oil supply had been not been maintained for greater than 16 days, including those four occasions. The inspectors determined that crediting the day tank supply, however, conflicts with the safety function of
the
- FO [[]]
ST, as described in the station's licensing basis, to be the sole source of the seven
days of supply. Specifically, at the end of seven days of
may be analyzed to be depleted, and not the day tank.
The safety function for the emergency AC power system with respect to the fuel oil supply is defined within the Final Safety Analysis Report, as updated in 2007, in Section 8.6,
"Emergency AC Power System" and specifically within Subsection 8.6.7, "Safety
Evaluation," by stating "The two diesel units comprising each emergency AC power source are capable of starting and operating continuously under postulated accident conditions
Enclosure for a period of seven days, using fuel stored in underground fuel storage tanks." This safety function design is consistent with Regulatory Guide 1.137, "Fuel-Oil Systems for Standby Diesel Generators," Revision 1 and
ANSI N195-1976, "American
National Standard for Fuel Oil Systems for Standby Diesel-Generators" and the most
recent revision
TSs (i.e. that after the sixteen days of allowed outage time the plant was required to begin shutting down, but did not). However, on
September 18, 2007, Entergy incorrectly concluded that no reportability criteria applied
and decided to not submit a 60-day report. Analysis: The
- NRC identified a performance deficiency in that Entergy did not provide a 60-day written report, as required by 10
CFR 50.73(a)(2)(i)(B). This violation involved a
failure to make a required report to the NRC and is considered to impact the regulatory
process. Such violations are dispositioned using the traditional enforcement process
instead of the Significance Determination Process. Using the Enforcement Policy Supplement I, "Reactor Operations," example D4 which states, "A failure to make a required
NRC determined this violation impacted the regulatory process and is
more than minor and categorized as a Severity Level IV violation.
Entergy's corrective actions included initiating
[[::JAF-2008-04323|JAF-2008-04323]] and filing LER 2009-
001, "Inadequate Engineering Calculation Results in Insufficient Inventory in
- EDG Fuel Oil Storage Tanks" on January 12, 2009. In addition, as part of the corrective actions already performed as part of
[[::JAF-2007-02490|JAF-2007-02490]], Entergy had revised
the applicable procedures to ensure the
- FO [[]]
STs contain adequate fuel oil inventory to
remain in compliance with the Technical Specifications and pursued license revisions to
the Technical Specifications to remove non-conservative values. The inspectors determined this finding had a cross-cutting aspect in the area of problem
identification and resolution within the corrective action program component because
Entergy personnel incorrectly concluded that the safety function to provide a seven day supply of fuel oil could utilize sources other than the
- FO [[]]
ST, specifically the day tank, and
therefore did not properly evaluate for reportability a condition adverse to quality on September 18, 2007. (P.1(c)) Enforcement:
LER for any operation or condition which was prohibited by the plant's Technical Specifications within 60 days of
discovering the event. Contrary to the above, Entergy failed to submit a report within 60 days of June 29, 2007, when the event associated with inadequate EDG fuel oil supply was discovered. Because this violation was of very low safety significance, was not
repetitive or willful, and it was entered into Entergy's corrective action program, this
violation is being treated as an
VI.A.1 of the
OA5 Other Activities .1 (Closed) Unresolved Item (URI) 05000333/2008003-01: Station Batteries With Indications On the Negative Plate Straps
Enclosure As documented in inspection report 05000333/2008003, the inspectors identified indications on the negative plate straps of multiple cells of station battery 71SB-1 and one
cell of station battery 71SB-2 that visually appeared to be cracks. Entergy removed cell
from service during their Fall 2008 refueling outage. Cell 23 was disassembled and the
negative plate strap was inspected in order to characterize the indication. Without electrolyte and container material to obscure the view, Entergy personnel determined that the suspected cracks were marks that appear on the surface against the
tooling and away from the welding torch and its operator. The tooling acts as a dam that
prevents molten lead from flowing into unintended areas. Lead in contact with the tooling
can develop thermal gradients causing it to freeze in shapes resembling plains, creases, striations, and laminations. In this case, the lead had frozen into shapes that resembled cracks. The inspectors reviewed Entergy's analysis, including photographs of the negative plate
strap with the electrolyte and container material removed, and concluded that the suspected cracks were surface anomalies. Therefore, no adverse condition existed and no violation of regulatory requirements was identified by the inspectors. URI 05000333/2008003-01, Station Batteries with Indications on the Negative Plate Straps, is
closed.
.2 Quarterly Resident Inspector Observations of Security Personnel and Activities a. Inspection Scope During the inspection period, the inspectors conducted observations of security force
personnel and activities to ensure that these activities were consistent with Entergy security procedures and applicable regulatory requirements. Although these observations did not constitute additional inspection samples, they were considered an integral part of
the normal, resident inspectors' plant status reviews during implementation of the baseline
inspection program.
b. Findings No findings of significance were identified. 4OA6 Meetings, Including Exit Exit Meeting Summary The inspectors presented the inspection results to Mr. P. Dietrich and other members of
Entergy's management at the conclusion of the inspection on April 9, 2009. The
inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
- ATTACH [[]]
- MENT [[:]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- ATION [[]]
- KEY [[]]
- POINTS [[]]
- OF [[]]
CONTACT Entergy Personnel P. Dietrich, Site Vice President C. Adner, Manager Operations
J. Barnes, Manager, Training and Development
P. Cullinan, Manager, Emergency Preparedness
B. Finn, Director Nuclear Safety Assurance D. Johnson, Manager, System Engineering J. LaPlante, Manager, Security
K. Mulligan, General Manager, Plant Operations
- LIST [[]]
- OF [[]]
- ITEMS [[]]
- AND [[]]
EDG fuel Oil Storage Tanks (Section 4OA3)
Discussed None
Attachment
- LIST [[]]
- OF [[]]
- DOCUME [[]]
- NTS [[]]
- REVIEW [[]]
RT-04.05, "Ice Potential Determination," Revision 1
OP-4, "Circulating Water System," Revision 63
Section
RHR-Low Pressure Coolant Injection," Revision 16
OP-14, "Core Spray System," Revision 31
OP-19, "Reactor Core Isolation Cooling System," Revision 46
Section
EL 286'-0", 326'-9", 344'-6" and EL 369'-6"," Revision 2
Section 1R11: Licensed Operator Requalification Program
SDIV Rupture After Manual Scram," Revision 4
DC-171, "Maintenance Rule Monitoring," Revision 2
Miscellaneous
ENN-MS-S-009-JAF, "JAF Safety System Function Sheets," Revision 1
Maintenance rule quarterly report 1st quarter 2008 Maintenance rule quarterly report 2nd quarter
- RPT -MISC-02272, "Maintenance Rule Basis Document for Plant Level Performance," Revision 7 Maintenance Rule Quarterly Report, 3rd quarter
RPT-ELEC-02302, "System 71-DC/DC Electrical Dist,: Revision 4
Attachment
- RPT -HPCI-02289, "Maintenance Rule Basis Document for System 023 High Pressure Coolant Injection System," Revision 5 System Health Report, 23 High Pressure Coolant Injection, 4th quarter 2008 System Health Report,
[[::JAF-2009-00274|JAF-2009-00274]]
Section 1R13: Maintenance Risk Assessments and Emergent Work Control AP-12.12, "Protected Equipment Program," Revision 4
AP-10.10, On-Line Risk Assessment; Revision 6
Section 1R15: Operability Evaluations
- LPCI Battery and Inverter On Line Testing Conditions and/or Limitations," Revision 0 Technical Specification Interpretation Number 29, "LPCI
[[::JAF-2009-00386|JAF-2009-00386]]
Section 1R19: Post Maintenance Testing
- APRM Upscale and Downscale Instrument Functional Test/Calibration" Revision 24 OP-16, "Neutron Monitoring," Revision 27
[[::JAF-2009-0088|JAF-2009-0088]]
- 9 ER [[]]
[[::JAF-04-13679|JAF-04-13679]], "RHRSW Keep-Full Check Valve Replacement," Revision 0
WO 180283-37, "Perform Oil Leak Test"
Attachment
- LP [[]]
CI Battery"
Section 1R22 Surveillance Testing
OP-37, "Containment Atmosphere Dilution System," Revision 77 OP-55A, "Control and Relay Room Refrigeration Water Chiller," Revision 21
Section 2OS3: Radiation Monitoring Instrumentation
Procedures
- ISP -95A, "Post Accident Containment High Range Radiation Monitor A Functional Test / Calibration," Revision 0
RESP-02.03, "Self-Contained Breathing Apparatus, Scott Pressure Pack 4.5," Revision 7
Attachment
SJAE Radiation Monitor Calibration," Revision 13
Audits/Assessments
JAF-0011, Review of Processes, Procedures & Controls for RP Instrumentation
Miscellaneous
RM-021-12, Spent Fuel Area RB 369' East. Temporary Set point Change
Scott PosiChek3, Visual / Functional Test Results,
OSC)
Scott PosiChek3, Visual / Functional Test Results, PAK2159, dated 6/17/2008 (Security)
Scott PosiChek3, Visual / Functional Test Results, PAK2157, dated 6/17/2008 (Security)
Breathing Air Quality / Activity Analysis, dated 10/30/2008 and 11/03/2008
RM-104B
Calibration & Functional Checks for Main steam line radiation monitors (17RM-251A/B/C/D)
- SCO [[]]
TT Authorized Service Center Maintenance & Overhaul Certifications
Daily Routine Surveys / Inspections Frisker Counting Equipment Inspections sheets
Electronic Dosimeter Response Test Records Calibration records for listed instruments Instrument Surveillance Records
Whole Body Counter Calibration and Response Checks
Section
- JAF -CALC-07-00020, "Revised Emergency Diesel Generator (EDG) Fuel Oil Storage Quantities for 7 Day and 6 Day Supplies," Revision
ME-G-001, "Evaluation of Pump Protection from Low Submergence," Revision 0 Condition Reports 2008-00916
2008-01113
2008-02602 2008-04467 2008-04468
2008-04608
2008-04610
2008-00781
2009-00284 2009-00350 2009-00360
2009-00378 2009-00380 2009-00382
2009-00381 2009-00384 2009-00385
2009-00386
2009-00872
2009-00884
2009-00906 2009-00924 2009-01019
2009-01021 2009-01053
Attachment
- LIST [[]]
- OF [[]]
- ACRONY [[]]
- MS [[]]
API American Petroleum Institute
- CREV [[]]
AS control room emergency ventilation air supply
EDG emergency diesel generator
Entergy Entergy Nuclear Northeast
FitzPatrick James
- HP [[]]
CI high pressure coolant injection
IMC inspection manual chapter
NCV non-cited violation NRC Nuclear Regulatory Commission
- PA [[]]
RS Publicly Available Record
- SJ [[]]
- UFS [[]]
AR updated final safety analysis report
URI unresolved item