IR 05000220/2008005
Download: ML090270145
Text
January 27, 2009
Mr. Keith Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT: NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2008005 and 05000410/2008005
Dear Mr. Polson:
On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, Units 1 and 2. The enclosed integrated inspection report documents the inspection results discussed on January 23, 2009, with you and 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.
This report documents one NRC-identified finding of very low safety significance (Green) which was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it was entered into your corrective action program (CAP), the NRC is treating this violation as a non-cited violation (NCV) in accordance with Section VI.A.1 of the NRC's Enforcement Policy. If you contest the NCV noted in this report, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C.
20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-001; and the NRC Senior Resident Inspector at Nine Mile Point Nuclear Station.
In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Original Signed By: Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects
Docket No.: 50-220, 50-410 License No.: DPR-63, NPF-69
Enclosure:
Inspection Report 05000220/2008005 and 05000410/2008005
w/Attachment:
Supplemental Information cc w/encl:
M. Wallace, Vice - Chairman, Constellation Energy H. Barron, President, CEO & Chief Nuclear Officer, Constellation Energy Nuclear Group C. Fleming, Esquire, Senior Counsel, Nuclear Generation, Constellation Energy Group, LLC M. Wetterhahn, Esquire, Winston & Strawn T. Syrell, Director, Licensing, Nine Mile Point Nuclear Station P. Tonko, President and CEO, New York State Energy Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority P. Eddy, New York State Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Supervisor, Town of Scriba P. Church, Oswego County Administator T. Judson, Central NY Citizens Awareness Network D. Katz, Citizens Awareness Network G. Detter, Manager, Nuclear Safety and Security, Constellation Energy
SUMMARY OF FINDINGS
............................................................................................................ 3
REPORT DETAILS
........................................................................................................................
REACTOR SAFETY
...................................................................................................................... 4 1R01 Adverse Weather Protection ....................................................................................... 4 1R04 Equipment Alignment .................................................................................................. 5
1R05 Fire Protection
............................................................................................................ 6 1R11 Licensed Operator Requalification Program ................................................................ 6
1R12 Maintenance Effectiveness .......................................................................................... 8 1R13 Maintenance Risk Assessments and Emergent Work Control
.................................... 9 1R15 Operability Evaluations ............................................................................................. 12 1R18 Plant Modifications .................................................................................................... 13 1R19 Post Maintenance Testing ........................................................................................ 13 1R20 Refueling and Other Outage Activities ...................................................................... 14 1R22 Surveillance Testing
RADIATION SAFETY
.................................................................................................................. 16 2OS1 Access Control to Radiologically Significant Areas ................................................... 16 2OS2 ALARA Planning and Controls .................................................................................. 17 2OS3 Radiation Monitoring Instrumentation and Protective Equipment .............................. 17 2PS2 Radioactive Material Processing and Transportation
OTHER ACTIVITIES
................................................................................................................... 20
4OA1 Performance Indicator Verification
............................................................................ 20
4OA2 Identification and Resolution of Problems
................................................................. 21
4OA3 Followup of Events and Notices of Enforcement Discretion
...................................... 25
4OA5 Other Activities ........................................................................................................... 26 4OA6 Meetings, including Exit ............................................................................................. 26 ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
..................................................................................................... A-1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
......................................................... A-1
LIST OF DOCUMENTS REVIEWED
......................................................................................... A-1
LIST OF ACRONYMS
- ...... ......................................................................................................... A-9
- OF [[]]
- FINDIN [[]]
GS
IR 05000220/2008005, 05000410/2008005; 10/01/08 - 12/31/08; Nine Mile Point Nuclear Station,
Units 1 and 2; Maintenance Risk Assessments and Emergent Work Control.
The report covered a three-month period of inspection by resident inspectors and regional
specialist inspectors. One Green NCV was 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)." Findings for which the SDP does not apply
may be Green or be assigned a severity level after
NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described in
- NUR [[]]
- A. [[]]
XVI, "Corrective Action," was identified on November 8, 2008 in that Nine
Mile Point Nuclear Station (NMPNS) did not take prompt action to verify that service
water (SW) pump performance had not been adversely affected following the
inadvertent introduction of a cleaning hose into the pump suction lines. This resulted
in delayed identification of two inoperable Unit 2 SW pumps due to fouling of the
impellers by foreign material that had been drawn into the pumps on November 4,
2008. As immediate corrective action, the affected pumps were disassembled and the
pieces of cleaning hose were removed. The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and affected the associated
cornerstone objective to limit the likelihood of those events that upset plant stability
and challenge critical safety functions during shutdown as well as power operations.
The finding was determined to be of very low safety significance in accordance with
Inspection Manual Chapter (IMC) 0609, Appendix A, "Determining the Significance of
Reactor Inspection Findings for At-Power Situations," based on a Phase 2 analysis
using the Nine Mile Point Unit 2 plant-specific Phase 2 pre-solved worksheets. The
finding had a cross-cutting aspect in the area of human performance because
- NMP [[]]
NS did not use conservative assumptions in decision making, in that they did not
timely verify the assumption that the cleaning hose was fully retrieved and had not
impacted operability of the service water pumps (H.1.b per IMC 0305). (Section
1R13)
- 4REPORT [[]]
DETAILS Summary of Plant Status
Nine Mile Point Unit 1 began the inspection period at full rated thermal power (RTP). On October
10, power was reduced to 70 percent for power suppression testing to identify and suppress a
leaking fuel bundle. This was completed on October 12 and power escalation was commenced,
with full RTP being reached on October 13. On October 23, operators inserted a manual scram
due to failure of the electronic pressure regulator (EPR) that caused a loss of reactor pressure
control. Following repair, a reactor startup was performed on October 26 and full RTP was
achieved on October 28. On November 1, power was reduced to 80 percent for a control rod
pattern adjustment, and was restored to full RTP later that day. On December 20, power was
reduced to 82 percent for a control rod pattern adjustment and turbine valve testing. Power was
restored to full RTP later that day, and remained there for the rest of the inspection period.
Nine Mile Point Unit 2 began the inspection period at full RTP. On October 18, power was
reduced to 67 percent for a control rod sequence exchange and single control rod scram time
testing. Power was restored to full RTP the following day. On November 13, Unit 2 shut down
for planned outage to replace the 'B' reactor recirculation pump seal package. A reactor startup
was performed on November 16 and full RTP was achieved on November 18. On December 3,
power was reduced to 80 percent to remove the 'E' main condenser water box from service due
to a tube leak. Power was restored to full RTP later that day. On December 6, power was
reduced to 65 percent to swap steam jet air ejectors, plug leaking main condenser tubes, and
perform turbine and main steam isolation valve (MSIV) testing. Power was restored to full
SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - Three samples) .1 Occurrences of Adverse Weather (One sample)
a. Inspection Scope On October 28, 2008, the inspectors reviewed
- NMP [[]]
NS's actions in response to a storm in
the vicinity of the station with wind gusting to 50 miles per hour. The inspectors verified
that both units implemented actions specified in their respective adverse weather
procedures to minimize the potential impact of the storm on the station. Unit 1 arranged
for deferral of offsite maintenance on one of the two 115 kilovolt (kV) offsite power lines
(line 4) that had been planned for that day. Unit 2 postponed maintenance on the Division
emergency diesel generator (EDG) until the following day, and deferred diving
operations in the service water (SW) intake bay to allow the traveling screens to be placed
in service. The storm had no adverse affect on the operation of either unit. Documents
reviewed for each section are listed in the Attachment.
b. Findings No findings of significance were identified.
.2 Readiness for Seasonal Extreme Weather Conditions (Two samples)
a. Inspection Scope The inspectors verified the seasonal readiness for Unit 1 and Unit 2 in accordance with
NAI-PSH-11, "Seasonal Readiness Program." The inspectors
reviewed and verified completion of the operations department cold weather preparation
checklists contained in procedures N1-OP-64 and N2-OP-102, "Meteorological
Monitoring," for Units 1 and 2, respectively. The inspectors toured selected areas at Unit
and Unit 2 to verify cold weather readiness. Additionally, the inspectors assessed the
readiness of the following risk significant systems that could be susceptible to the effects
of cold weather:
- Unit
EDGs; and * Unit 2 SW system. b. Findings No findings of significance were identified. 1R04 Equipment Alignment (71111.04 - Three samples) a. Inspection Scope The inspectors performed partial system walkdowns to verify risk-significant systems were
properly aligned for operation. The inspectors verified the operability and alignment of
these risk-significant systems while their redundant trains or systems were inoperable or
out of service for maintenance. The inspectors compared system lineups to system
operating procedures, system drawings, and the applicable chapters in the updated final
safety analysis report (UFSAR). The inspectors verified the operability of critical system
components by observing component material condition during the system walkdown.
The inspectors performed partial walkdowns of the following systems:
- Unit 1 containment spray raw water system due to its high safety significance as the ultimate heat sink; * Unit 2 Division
EDG was inoperable and unavailable; and * Unit 2 reactor core isolation cooling (RCIC) system due to it being a high safety significance single train system.
b. Findings No findings of significance were identified. 1R05 Fire Protection (71111.05Q - Five samples) a. Inspection Scope The inspectors toured areas important to reactor safety at
- NMP [[]]
NS to evaluate the
station's control of transient combustibles and ignition sources, and to examine the
material condition, operational status, and operational lineup of fire protection systems including detection, suppression, and fire barriers. The inspectors evaluated fire
protection attributes using the criteria contained in Unit
- 1 UFS [[]]
AR Appendix 10A, "Fire
Hazards Analysis," and Unit 2 procedure N2-FPI-PFP-0201, "Unit 2 Pre-Fire Plans." The
areas inspected included:
- Unit 1 screen house; * Unit 1 diesel fire pump room; * Unit 2 low pressure core spray pump room, north auxiliary bay 175 foot elevation; * Unit 2 Division 1 cable spreading room, control building (CB) 237 foot elevation; and * Unit 2 Division 1 switchgear room, CB 261 foot elevation.
b. Findings No findings of significance were identified. 1R11 Licensed Operator Requalification Program .1 Quarterly Review (71111.11Q - Two samples) a. Inspection Scope
The inspectors evaluated two simulator scenarios in the licensed operator requalification
training (LORT) program. The inspectors assessed the clarity and effectiveness of
communications, the implementation of appropriate actions in response to alarms, the
performance of timely control board operation, and the oversight and direction provided by
the shift manager. During the scenario, the inspectors also compared simulator
performance with actual plant performance in the control room. The following scenarios
were observed:
- On November 4, 2008, the inspectors observed Unit
- 1 LO [[]]
RT to assess operator and instructor performance during a scenario involving loss of reactor protection system
motor generator 131, spurious opening of an emergency relief valve, and a steam leak
with failure of a torus-to-drywell vacuum breaker. The inspectors evaluated the
performance of risk significant operator actions including the use of special operating
procedures (SOPs) and emergency operating procedures (EOPs).
7* On October 14, 2008, the inspectors observed Unit
- 2 LO [[]]
RT to assess operator and instructor performance during a scenario involving a main turbine electro-hydraulic
control system pressure regulator malfunction that caused power to increase, a control
rod drifting out of the core, a loss of all reactor building closed loop cooling system
main pumps, and a failed-open safety relief valve with a break in the tailpiece above
the suppression chamber that required operators to perform a reactor pressure vessel
blowdown due to high drywell pressure. The inspectors evaluated the performance of
risk significant operator actions including the use of
EOPs.
b. Findings No findings of significance were identified.
.2 Biennial Review (71111.11B - One sample)
a. Inspection Scope The following inspection activities were performed using
- NUR [[]]
EG 1021, "Operator
Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1,
Inspection Procedure Attachment 71111.11, "Licensed Operator Requalification
Program," Appendix A, "Checklist for Evaluating Facility Testing Material," and Appendix B
"Suggested Interview Topics." A review was conducted of recent operating history documentation found in inspection
reports, licensee event reports (LERs), the licensee's corrective action program (CAP),
and the most recent NRC plant issues matrix. The inspectors also reviewed specific
events from the licensee's CAP which indicated possible training deficiencies, to verify that they had been appropriately addressed. The senior resident inspector was also
consulted for insights regarding licensed operators' performance. These reviews
indicated a potential area for improvement in recognizing off normal equipment status
below any alarm threshold. The operating and written tests for two of the six exam weeks were reviewed for quality
and performance. Compliance with overlap controls of the facility program was verified. On September 19, 2008, the results of the Unit 1 biennial written examination for 2008
and the annual operating tests for both units for 2008 were reviewed against the criteria of
- NUR [[]]
EG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision
9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, "Operator Requalification
Human Performance SDP." The review verified the following:
For Unit 1 $ Crew pass rates were greater than 80% (Pass rate was 83.3%); $ Individual pass rates on the written exam were greater than 80% (Pass rate was 97.3%); $ Individual pass rates on the job performance measures (JPMs) of the operating exam were greater than 80% (Pass rate was 97.3%); and
8$ More than 75% of the individuals passed all portions of the exam (86.5% of the individuals passed all portions of the examination). For Unit 2 $ Crew pass rates were greater than 80% (Pass rate was 100%); $ No biennial written examination was administered this year; $ Individual pass rates on the
- JPM [[s of the operating exam were greater than 80% (Pass rate was 98%); and $ More than 75% of the individuals passed all portions of the exam (90% of the individuals passed all portions of the examination). Observations were made of the dynamic simulator exams and]]
JPMs administered during
the week of the inspection. These observations included facility evaluations of crew and
individual performance during the dynamic simulator exams and individual performance of
five JPMs. The remediation plans for one crew operating test failure and four individual operating test
failures were reviewed to assess the effectiveness of the remedial training.
Operators, instructors and training/operations management were interviewed for feedback
on their training program and the quality of training received. Simulator performance and fidelity were reviewed for conformance to the reference plant
control room. A sample of administrative records was reviewed for compliance with license conditions,
including NRC regulations. This sample included one year of requalification attendance
records, two years of licensed operator watchstanding proficiency and license reactivation
records, and ten licensed operator medical records.
b. Findings No findings of significance were identified. 1R12 Maintenance Effectiveness (71111.12Q - Two samples) a. Inspection Scope The inspectors reviewed performance-based problems and the performance and
condition history of selected systems to assess the effectiveness of the maintenance
program. The inspectors reviewed the systems to ensure that the station's review
focused on proper maintenance rule scoping in accordance with 10 CFR Part 50.65,
characterization of reliability issues, tracking system and component unavailability, and 10
CFR Part 50.65 (a)(1) and (a)(2) classification. In addition, the inspectors reviewed the
site's ability to identify and address common cause failures and to trend key parameters.
The following maintenance rule inspection samples were reviewed:
9* Unit 1 emergency cooling system, based on repeat problems with main steam vent isolation valves; and * Unit
- 2 RC [[]]
IC system, based on repeated trip relay failures.
b. Findings No findings of significance were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Six samples) a. Inspection Scope The inspectors evaluated the effectiveness of the maintenance risk assessments required
by 10 CFR Part 50.65 (a)(4). The inspectors reviewed equipment logs, work schedules,
and performed plant tours to verify that actual plant configuration matched the assessed
configuration. Additionally, the inspectors verified that risk management actions for both
planned and emergent work were consistent with those described in station procedures.
The inspectors reviewed risk assessments for the activities listed below. Unit 1 * Week of October 6, which included containment spray 122 quarterly surveillance, EDG 103 monthly surveillance, and an emergent activity to perform power
suppression testing to identify and suppress a leaking fuel bundle. * Week of November 3, which included EDG 103 monthly surveillance, containment spray 121 quarterly surveillance and heat exchanger performance testing, an
extended maintenance period for 12 instrument air compressor, off-site 115 kV line 4
out of service for two days for off-site maintenance, and calibration of the average
power range monitoring system using the traversing in-core probe system. * Week of November 17, which included 111 and 121 core spray system quarterly surveillances, 111 containment spray heat exchanger performance testing, a three
day outage for
EDG 102 monthly
surveillance. Unit 2 * Week of October 13, which included
EDG monthly surveillance, a two day maintenance period for the Division 1 residual heat removal
(RHR) system, Division 1 RHR quarterly surveillance, a power reduction to 65 percent
for a control rod pattern exchange and single control rod scram time testing, and an
emergent issue to repair the 'B'
discharge strainer and to remove foreign material from the 'C' and 'F' SW pumps.
10 * Week of December 1, which included Division 2 standby liquid control system valve maintenance and quarterly surveillance, Division 2 SW pumps quarterly surveillance,
Division 2 EDG annual 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run surveillance, and emergent maintenance to repair
the 'E' SW discharge strainer. In addition, the week included the identification of lake
water inleakage to the condensate system which led to a 20 percent power reduction
to remove the 'E' main condenser waterbox from service, and a subsequent power
reduction to 65 percent to conduct repairs and swap steam jet air ejectors.
b. Findings
Introduction. An
- NMP [[]]
NS did not take
prompt action to verify that SW pump performance had not been adversely affected
following the inadvertent introduction of a cleaning hose into the pump suction lines. This
resulted in delayed identification of two inoperable Unit 2 SW pumps due to fouling of the
impellers by foreign material that had been drawn into the pumps on November 4, 2008. Description. The Unit 2 SW system has six pumps (A-F), with three in each of the two Divisional subsystems (A, C, and E in Division 1, and B, D, and F in Division 2). The
subsystems are normally cross-connected, with two pumps operating in each subsystem. On the morning of November 4, 2008, divers were cleaning the Unit 2 SW intake bay
using a vacuum device that was connected to a six inch diameter plastic hose. At 11:43
a.m., operators in the control room received an alarm that indicated low suction pressure
for the Division
pump. The control room operators contacted the diving supervisor, who informed them
that the cleaning vacuum hose had inadvertently been drawn into the suction pipe for the
'C'
SW pump was started to allow the 'C' SW pump to be secured, and
the hose was withdrawn. At about 12:45 p.m., a similar event occurred with the 'F'
SW pump was secured, and the hose was
withdrawn. Cleaning operations were secured and the cleaning vacuum hose was
removed from the water. Although the end of the hose had broken into several pieces,
- NMPNS determined incorrectly that all of the hose had been retrieved. Later on November 4, the inspectors noted that the discharge flow for the 'C'
SW pump
appeared to be lower than normal. The control room operators responded that the lower
flow was normal for the existing pump combination. On November 7, 2008, the 'F' SW pump was started as part of a planned pump swap.
This was the first time that the pump had been operated since it had been secured on
November 4 to allow removal of the cleaning vacuum hose. An operator reported that the
pump had made an abnormal noise just after it had been started, and control room
operators observed abnormally low discharge flow. The 'F' SW pump was secured and
declared inoperable. Disassembly of the pump revealed that approximately five feet of
cleaning vacuum hose was lodged in the pump casing and impeller. The 'F' SW pump
was restored to a functional status on November 8 at 5:31 p.m.
11Because the November 7 issue with the 'F' SW pump confirmed that all of the cleaning vacuum hose had not actually been retrieved on November 4, the inspectors questioned
whether additional action would be taken to verify that the 'C' SW pump had not been
similarly impacted.
SW pump quarterly surveillance would be
performed to verify the operability of all of the remaining SW pumps. During this test,
operators were unable to achieve the required parameters for the 'C' SW pump, and the
pump was declared inoperable. Test results for the remaining SW pumps were
satisfactory. On November 9 at 2:54 a.m., the 'C' SW pump was declared unavailable to
support disassembly; approximately one foot of cleaning suction hose was found lodged
in the impeller. The 'C' SW pump was returned to a functional status at 5:45 p.m. on
November 9.
SW pump had been functional
between November 4, when the hose had been sucked into the pump, and November 9,
when the pump was declared inoperable and disassembled. The inspector agreed with
this determination, because, while the pump was inoperable (pump differential pressure
degraded below the in-service test requirement), it still would have supported SW system
operability in combination with any of the remaining operable SW pumps. As immediate corrective action for this event, the affected pumps were disassembled and
the foreign material was removed. These issues were entered into the CAP as condition
report (CR) 2008-8430 for the 'F'
NMPNS did not promptly
verify that ingestion of the cleaning vacuum hose into the 'C' and 'F' SW pump suction
lines had not adversely affected the performance of the pumps. Corrective action to
address the failure to promptly verify
CR
2008-8492. Analysis. The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affects the associated
cornerstone objective to limit the likelihood of those events that upset plant stability and
challenge critical safety functions during shutdown as well as power operations. Per
inspection manual chapter (IMC) 0609, Attachment 0609.04, "Initial Screening and
Characterization of Findings," the inspectors conducted a Phase 1 screening and
determined that this finding required a Phase 2 analysis because the finding contributed
to both the likelihood of a reactor trip and the likelihood that mitigation equipment
functions would not be available. The inspectors determined that the finding was of very low safety significance (Green)
using the Unit 2 plant-specific Phase 2 pre-solved worksheets, which include large early
release frequency and external events, in accordance with IMC 0609, Appendix A,
"Determining the Significance of Reactor Inspection Findings for At-Power Situations."
The following assumptions were made during the evaluation: 1) the reactor was operating
at full power; 2) the 'C'
SW pump was not
functional; 3) the 'F' SW pump was unavailable for greater than three days but less than
days (approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> from when the hose was drawn into the suction pipe
and the pump was secured on November 4 until it was restored to available status on
2November 8); and 4) the approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> that the 'C' SW pump was not functional (November 9, while the pump was disassembled), would not add significantly to the result.
The risk increase was dominated by the internal core damage frequency increase which
was conservatively estimated to be in the mid E-7/year range. The dominate core
damage sequence was based on the increased frequency of a loss of SW initiating event,
due to loss of SW pump redundancy, and included the failure of containment heat
removal, failure to vent the containment, and failure of low pressure injection sources
following containment failure. The finding had a cross-cutting aspect in the area of human performance because
- NMP [[]]
NS did not use conservative assumptions in decision making, in that they did not
timely verify the assumption that the cleaning hose was fully retrieved and had not
impacted operability of the service water pumps (H.1.b per
CFR 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, "Measures shall be established to assure that conditions adverse to quality, such as
failures, malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformance are promptly identified and corrected." Contrary to the above, on
November 4 until November 8, 2008,
- NMP [[]]
NS did not promptly identify that introduction of
foreign material into the 'C' and 'F'
- SW pumps. This resulted in inoperability of the pumps. Because this noncompliance is of very low safety significance and was entered into the
CAP as CRs 2008-8430, 2008-
8444, and 2008-8492, this violation is being treated as an
NCV 05000410/2008005-01, Untimely Corrective Action for Degraded Service Water Pumps) 1R15 Operability Evaluations (71111.15 - Five samples) a. Inspection Scope The inspectors evaluated the acceptability of operability evaluations, the use and control
of compensatory measures, and compliance with technical specifications (TSs). The
evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary
2005-20, "Revision to Guidance Formerly Contained in NRC Generic Letter 91-18,
'Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution
of Degraded and Nonconforming Conditions and on Operability'," and Inspection Manual
Part 9900, "Operability Determinations and Functionality Assessments for Resolution of
Degraded or Nonconforming Conditions Adverse to Quality or Safety." The inspectors'
review included verification that the operability determinations were made as specified by
Procedure
OP-1.01-1002, "Conduct of Operability Determinations / Functionality
Assessments." The technical adequacy of the determinations was reviewed and
compared to the
UFSAR, and associated design basis documents (DBDs).
The following evaluations were reviewed:
- CR 2008-8383 concerning the post-accident monitoring reliability of Unit 1 drywell pressure instruments following a postulated fuel failure and design basis loss of
coolant accident;
13*
- CR 2008-7690 concerning divergence of two channels of the Unit 2 leak detection system differential temperature monitors for the main steam tunnel; *
- SW pump without strainer backwash in service due to broken shear pins in the rotating mechanism; and *
CR 2008-8518 concerning the Unit 2 TS-required determination of acceptability for continued operation of the reactor coolant system following a cooldown of greater than
100 degrees Fahrenheit (F) in a one hour period.
b. Findings No findings of significance were identified.
1R18 Plant Modifications (71111.18 - One sample) a. Inspection Scope The inspectors reviewed a Unit 2 temporary modification that installed a blowdown valve
at a low point of the instrument air system for removal of condensation in the system. It
was installed to reduce air moisture content and prevent condensation in air operated
components that could result in component malfunction. The inspectors reviewed the
modification package and discussed its installation with mechanical engineering
personnel. The inspectors evaluated the modification against the system design
attributes listed in Unit
- 2 UFS [[]]
AR Section 9.3.1.1, "Instrument Air System."
b. Findings No findings of significance were identified. 1R19 Post Maintenance Testing (71111.19 - Four samples) a. Inspection Scope The inspectors reviewed the post maintenance tests (PMTs) listed below to verify that
procedures and test activities ensured system operability and functional capability. The
inspectors reviewed the test procedure to verify that the procedure adequately tested the
safety functions that may have been affected by the maintenance activity, that the
acceptance criteria in the procedure were consistent with information in the applicable
licensing basis and/or DBDs, and that the procedure had been properly reviewed and
approved. The inspectors also witnessed the test or reviewed test data, to verify that the
test results adequately demonstrated restoration of the affected safety functions. * Unit 1, Work Order (WO) 08-01313-00 to replace solenoid operated valves 113-273 and 113-274 for air operated valves 44.2-18 and 44.2-15 that control the vent and
drain valves for the scram discharge volume, due to slow closure time after the
October 23 scram. The PMT was to stroke time the vent and drain valves open and
closed, in accordance with the WO step text.
14 * Unit 1,
- WO 07-03553-00 for preventive maintenance on drywell nitrogen containment isolation valve air regulators. The
PMT was to exercise the valves in accordance with
procedure N1-ST-Q5, "Primary Containment Isolation Valves Operability Test." * Unit 2,
- MS [[]]
IV having cycled without operator action following slow
closure. The
MSS*7C fast closure stroke timing in accordance
with N2-OSP-MSS-CS001, "MSIV Operability Test," perform 2MSS*7C slow closure in
accordance with N2-OP-1, "Main Steam System," and verify proper solenoid operating
currents in accordance with N2-OSP-LOG-W001, "Weekly Checks." * Unit 2,
- WO 08-10810-00 to recondition or replace Division 1 standby liquid control pump suction and discharge valves in accordance with N2-
MPM-SLS-V143, "Standby
Liquid Control Pumps
PMT was to operate the pump at
normal flow and test pressure in accordance with N2-OSP-SLS-Q001, "Standby Liquid
Control Pump, Check Valve, Relief Valve Operability Test and
- ASME [[]]
XI Pressure
Test."
b. Findings No findings of significance were identified.
1R20 Refueling and Other Outage Activities (71111.20 - Two samples)
.1 Unit 1 Forced Outage
a. Inspection Scope
The inspectors observed and reviewed the following activities during the Unit 1 forced
outage from October 23 to October 26, 2008.
The inspectors observed portions of the plant shutdown and cooldown and verified that
the TS cooldown rate limits were satisfied. The inspector reviewed outage schedules and
procedures, and verified that TS specified safety system availability was maintained and
that shutdown risk was considered.
The inspectors observed portions of the reactor startup following the outage, and verified
through control room observations, discussions with personnel, and log reviews that
safety-related equipment specified for mode change was operable.
b. Findings No findings of significance were identified.
15.2 Unit 2 Planned Outage
a. Inspection Scope The inspectors observed and reviewed the following activities during the Unit 2 planned
outage from November 13 to November 16, 2008.
The inspectors observed portions of the plant shutdown and cooldown. The inspectors
reviewed outage schedules and procedures, and verified that TS specified safety system
availability was maintained and that shutdown risk was considered.
The inspectors performed a walkdown of accessible areas of the drywell to identify
evidence of reactor coolant system leakage, and verify the condition of drywell coatings,
structures, valves, piping, supports, and other equipment.
The inspectors observed portions of the reactor startup following the outage, and verified
through control room observations, discussions with personnel, and log reviews that
safety-related equipment specified for mode change was operable.
b. Findings No findings of significance were identified. 1R22 Surveillance Testing (71111.22 - Four samples) a. Inspection Scope The inspectors witnessed performance of and/or reviewed test data for risk-significant
surveillance tests to assess whether the components and systems tested satisfied design
and licensing basis requirements. The inspectors verified that test acceptance criteria
were clear, demonstrated operational readiness and were consistent with the DBDs; that
test instrumentation had current calibrations and the range and accuracy for the
application; and that tests were performed, as written, with applicable prerequisites
satisfied. Upon test completion, the inspectors verified that equipment was returned to
the status specified to perform its safety function.
The following surveillance tests were reviewed:
- N1-SST-Q6D, "Containment Spray System Loop 122 Quarterly Operability Test;" * N1-ST-M1A, "Liquid Poison Pump 11 Operability Test;" * N2-OSP-RHS-Q@006, "RHR System Loop C Pump and Valve Operability Test and System Integrity Test;" and * N2-ESP-ENS-Q731, "Quarterly Channel Functional Test of
LPCI [low pressure core spray/low pressure coolant injection] Pumps A, B, and C (Normal and Emergency
Power) Auto Start Time Delay Relays."
16 b. Findings No findings of significance were identified. 2.
- RADIAT [[]]
- ION [[]]
OS1 Access Control to Radiologically Significant Areas (71121.01 - Seven samples)
a. Inspection Scope The inspectors reviewed all licensee performance indicators (PIs) for the occupational
radiation safety cornerstone for follow-up. The inspectors reviewed the licensee's self assessments, audits, LERs, and Special
Reports related to the access control program since the last inspection. The inspectors
verified that identified problems were entered into the CAP for resolution. The inspectors reviewed corrective action reports related to access controls. The
inspectors interviewed staff and reviewed documents to determine if the activities are
being conducted in an effective and timely manner commensurate with their importance to
safety and risk:
- Initial problem identification, characterization, and tracking; * Disposition of operability/reportability issues; * Evaluation of safety significance/risk and priority for resolution; * Identification of repetitive problems; * Identification of contributing causes; * Identification and implementation of effective corrective actions; * Resolution of NCVs tracked in the corrective action system; and * Implementation/consideration of risk significant operational experience feedback.
For repetitive deficiencies or significant individual deficiencies in problem
identification and resolution identified above, the inspectors determined if the licensee's
self-assessment activities were also identifying and addressing these deficiencies. The inspectors reviewed licensee documentation packages for all PI events occurring
since the last inspection. The inspectors determined if any of these PI events involved
dose rates >25 rad per hour (R/hr) at 30 centimeters or >500 R/hr at 1 meter. If so, the
inspectors determined what barriers had failed and if there were any barriers left to
prevent personnel access. For unintended exposures >100 millirem (mrem) total effective
dose equivalent (TEDE) (or >5 rem skin dose equivalent (SDE) or >1.5 rem lens dose
equivalent (LDE)), the inspectors determined if there were any overexposures or
substantial potential for overexposure. The inspectors reviewed any radiological problem reports since the last inspection which
were attributed to radiation worker errors. The inspectors evaluated whether there was an
17observable pattern traceable to a similar cause. The inspectors determined if this perspective matched the corrective action approach taken by the licensee to resolve the
reported problems. The inspectors discussed with the radiation protection manager any
problems with the correction actions planned or taken. The inspectors reviewed any radiological problem reports since the last inspection
which were attributed to radiation protection technician errors. The inspectors determined
if there was an observable pattern traceable to a similar cause. The inspectors
determined if this perspective matched the corrective action approach taken by the
licensee to resolve the reported problems.
The inspectors evaluated licensee performance against the requirements contained in
b. Findings No findings of significance were identified.
ALARA Planning and Controls (71121.02 - Two samples)
a. Inspection Scope The inspectors reviewed the licensee's self assessments, audits, and Special Reports
related to the as low as reasonably achievable (ALARA) program since the last inspection.
The inspectors determined if the licensee's overall audit program's scope and frequency
(for all applicable areas under the Occupational Radiation Safety Cornerstone) met the
requirements of 10 CFR 20.1101(c). For repetitive deficiencies or significant individual deficiencies in problem
identification and resolution identified above, the inspectors determined if the licensee's
self-assessment activities were also identifying and addressing these deficiencies.
The inspectors evaluated licensee performance against the requirements contained in
CFR 20.1101.
b. Findings No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - Two samples)
a. Inspection Scope The inspectors reviewed CAP reports related to exposure significant radiological incidents
that involved radiation monitoring instrument deficiencies since the last inspection in this
area. The inspectors interviewed staff and reviewed documents to determine if the
following activities were being conducted in an effective and timely manner commensurate
18with their importance to safety and risk: * Initial problem identification, characterization, and tracking; * Disposition of operability/reportability issues; * Evaluation of safety significance/risk and priority for resolution; * Identification of repetitive problems; * Identification of contributing causes; * Identification and implementation of corrective actions which will achieve lasting results; * Resolution of NCVs tracked in corrective action system(s); and * Implementation/consideration of risk significant operational experience feedback. For repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified above, the inspectors determined if the licensee's self-assessment
activities are also identifying and addressing these deficiencies.
The inspectors evaluated licensee performance against the requirements contained in
CFR 20.1703 and 10 CFR 20.1704.
b. Findings No findings of significance were identified.
2PS2 Radioactive Material Processing and Transportation (71122.02 - Six samples)
a. Inspection Scope The inspectors reviewed the solid radioactive waste system description in the
- UFS [[]]
AR and
the recent radiological effluent release report for information on the types and amounts of
radioactive waste disposed. The inspectors reviewed the scope of the licensee's audit
program to verify that it meets the requirements of 10 CFR 20.1101(c). The inspectors walked-down the liquid and solid radioactive waste processing systems to
verify and assess that the current system configuration and operation agree with the
descriptions contained in the
PCP). The
inspectors reviewed the status of any radioactive waste process equipment that was not
operational and/or was abandoned in place. The inspectors reviewed the licensee's
administrative and physical controls to ensure that the equipment will not contribute to an
unmonitored release path and/or affect operating systems or be a source of unnecessary
personnel exposure.
The inspectors reviewed the adequacy of any changes made to the radioactive waste
processing systems since the last inspection. The inspectors verified that the changes
were reviewed and documented in accordance with 10 CFR 50.59, as appropriate. The
inspectors reviewed the impact, if any, to radiation doses to members of the public. The
inspectors reviewed current processes for transferring radioactive waste resin and sludge
discharges into shipping/disposal containers to determine if appropriate waste stream
19mixing and/or sampling procedures, and methodology for waste concentration averaging, provide representative samples of the waste product for the purposes of waste
classification as specified in 10 CFR 61.55 for waste disposal. The inspectors reviewed the radio-chemical sample analysis results for each of the
licensee's radioactive waste streams. The inspectors reviewed the licensee's use of
scaling factors and calculations used to account for difficult-to-measure radionuclides.
The inspectors verified that the licensee's program assures compliance with
CFR Part 20. The inspectors
reviewed the licensee's program to ensure that the waste stream composition data
accounts for changing operational parameters and thus remains valid between the annual
or biennial sample analysis update.
The inspectors observed shipment packaging, surveying, labeling, marking, placarding,
vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors verified that
the requirements of any applicable transport cask Certificate of Compliance had been
met. The inspectors verified that the receiving licensee is authorized to receive the
shipment packages. The inspectors observed radiation workers during the conduct of
radioactive waste processing and radioactive material shipment preparation activities.
The inspectors determined if the shippers were knowledgeable of the shipping regulations
and whether shipping personnel demonstrated adequate skills to accomplish the package
preparation requirements for public transport with respect to NRC Bulletin 79-19 and 49
CFR Part 172 Subpart H. The inspectors verified that the licensee's training program
provided training to personnel responsible for the conduct of radioactive waste processing
and radioactive material shipment preparation activities. The inspectors sampled non-excepted package shipment records. The inspectors
reviewed these records for compliance with NRC and Department of Transportation
(DOT) requirements. The inspectors reviewed the licensee's LERs, Special Reports, audits, State agency
reports, and self assessments related to the radioactive material and transportation
programs performed since the last inspection. The inspectors determined if identified
problems are entered into the CAP for resolution. The inspectors reviewed corrective
action reports written against the radioactive material and shipping programs since the
previous inspection. The inspectors interviewed staff and reviewed documents to determine if the following
activities were being conducted in an effective and timely manner commensurate with
their importance to safety and risk:
- Initial problem identification, characterization, and tracking; * Disposition of operability/reportability issues; * Evaluation of safety significance/risk and priority for resolution; * Identification of repetitive problems; * Identification of contributing cause;
20* Identification and implementation of effective corrective actions; * Resolution of NCVs tracked in corrective action system(s); and * Implementation/consideration of risk significant operational experience feedback. For repetitive deficiencies or significant individual deficiencies in problem
identification and resolution identified above, the inspectors determined if the licensee's
self-assessment activities were also identifying and addressing these deficiencies.
b. Findings No findings of significance were identified. 4.
- OTHER [[]]
- 4OA 1 Performance Indicator Verification (71151 - Twelve samples) a. Inspection Scope The inspectors sampled
NMPNS submittals for the PIs listed below. To verify the
accuracy of the
PI definition guidance contained in
Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator
Guideline," Revision 5, was used to verify the basis in reporting for each data element.
Cornerstone: Mitigating Systems
The inspectors reviewed
- NMP [[]]
NS's submittals for the Mitigating System Performance
Indicators (MSPIs) listed below to determine the accuracy and completeness of the
reported data. The review was accomplished by comparing the reported PI data to plant
records and information available in plant logs,
NRC inspection reports. The definitions and guidance in
NEI 99-02, formed the basis for the review. The results were discussed with the
cognizant engineering and licensing personnel. Operating data for the period of October
2007 through September 2008 were reviewed to complete this inspection.
- Unit 1 emergency alternating current (AC) power system; * Unit 1 high pressure injection system; * Unit 1 heat removal system; * Unit
AC power system; * Unit 2 high pressure injection system; * Unit 2 heat removal system; * Unit 2 RHR system; and * Unit 2 cooling water systems.
21Cornerstone: Occupational Radiation Safety
The inspectors reviewed all licensee PIs for the Occupational Radiation Safety
Cornerstone for follow-up. The inspectors reviewed a listing of licensee action reports for
the period January 1, 2008, through November 17, 2008, for issues related to the
- PI , which measures non-conformances with high radiation areas greater than 1R/hr and unplanned personnel exposures greater than 100 mrem
PI events involved dose rates >25 R/hr at
centimeters or >500 R/hr at 1 meter. If so, the inspector determined what barriers had
failed and if there were any barriers left to prevent personnel access. For unintended
exposures >100 mrem
- TEDE [[(or >5 rem]]
SDE or >1.5 rem LDE), the inspector determined
if there were any overexposures or substantial potential for overexposure. The inspectors
compared the results with the reported data.
Cornerstone: Public Radiation Safety The inspectors reviewed a listing of licensee action reports for the period January 1, 2008
through December 8, 2008 for issues related to the public radiation safety PI, which
measures radiological effluent release occurrences per site that exceed 1.5 mrem/quarter
(qtr) whole body or 5 mrem/qtr organ dose for liquid effluents; or 5 mrads/qtr gamma air
dose, 10 mrads/qtr beta air dose; or 7.5 mrems/qtr organ doses from I-131, I-133, H-3
and particulates for gaseous effluents. The inspectors compared the results with the
reported data.
b. Findings No findings of significance were identified.
- 4OA 2 Identification and Resolution of Problems (71152 - Four samples) .1 Review of Items Entered into the
a. Inspection Scope As specified by Inspection Procedure 71152, "Identification and Resolution of Problems,"
and in order to help identify repetitive equipment failures or specific human performance
issues for follow-up, the inspectors performed a daily screening of items entered into
CAP. In accordance with the baseline inspection procedures, the inspectors
also identified selected CAP items across the initiating events, mitigating systems, and
barrier integrity cornerstones for additional follow-up and review. The inspectors
assessed the threshold for problem identification, the adequacy of the cause analyses,
extent of condition review, operability determinations, and the timeliness of the specified
corrective actions.
2 b. Findings No findings of significance were identified.
.2 Semi-Annual Review to Identify Trends (One sample)
a. Inspection Scope As specified by Inspection Procedure 71152, "Identification and Resolution of Problems,"
the inspectors reviewed
CAP and associated documents to identify trends that
could indicate significant safety issues and/or low level trends before they become
significant. The inspectors' review focused on repetitive equipment and corrective
maintenance issues, and considered the results of the daily inspector CAP item
screening. The review included issues documented outside of the normal CAP, such as
system health reports, quality performance reports, quality assurance assessment
reports, maintenance rule status reports, operator workaround lists, and the governing
procedure. The inspectors' review considered the period of June through November
2008.
b. Assessments and Observations No findings of significance were identified. The inspectors did not identify any equipment
or performance trends that had not already been noted in departmental quarterly
assessments.
CAP,
which allowed for the identification of low-level trends before the issue became significant.
.3 Annual Sample - Unit 1 Operator Workarounds (One sample) a. Inspection Scope The inspectors reviewed the Unit 1 operator workarounds, operator burdens, and
operations items of interest, defeated annunciators, control room deficiencies, and open
operability determinations. The review focused on the reliability and availability of
mitigating systems with particular focus on issues that had the potential to affect the ability
of operators to respond to plant transients and events. Also, the inspectors reviewed the
governing procedure,
REL-02, "Control of Operator Workarounds, Burdens, and
Interests." The inspectors interviewed operations personnel on their knowledge of
selected workarounds and the associated compensatory actions. In addition, the
inspectors discussed with engineering and operations management the planned
corrective actions for restoration of some of the degraded systems. b. Assessment and Observations No findings of significance were identified. None of the identified issues, individually or in the aggregate, appear to have a negative impact on the ability of the operators to
complete actions in procedures, or to significantly affect the timeliness of those actions.
The inspectors identified one issue which had been removed from the workaround list
without adequate corrective actions being taken. Specifically, the inspectors identified
23that the Unit 1 Shutdown Cooling System outboard isolation valve (SDC IV-38-02), which was placed on the list in August 2004, was removed from the Operator Workaround List
because the nonconforming condition was "accepted-as-is."
Nine Mile Point administrative instruction
REL-02, "Control of Operator Workarounds,
Burdens, and Interests," Section 3.5.2, states: "A workaround / burden can be resolved
as an 'Accept-As-Is' condition. In this case the Operations Manager must approve the
'Accept-As-Is' resolution." Section 3.5.3 states, in part, "If a workaround will be resolved
by an 'Accept-As-Is' condition . . . Confirm that any compensatory/manual measures have
been appropriately . . . proceduralized."
The issue was first documented in
CR noted
that the breaker for IV-38-02 tripped while trying to open the valve from the control room.
The cause was determined to be thermal binding; the valve has a solid wedge disc which
is sensitive to temperature differentials between the valve body and disc. One of the
corrective actions was to revise N1-OP-4, "Shutdown Cooling System," to manually open
the valve off the valve seat with a torque wrench, and then complete opening the valve
from the control room. As part of the procedure change process,
- NMP [[]]
NS completed a 10
CFR 50.59 Screening Form but failed to recognize/identify that the system operation was
described in the Unit
UFSAR,Section X.A.2, states that the shutdown
cooling system may be manually actuated from the main control room. The consequence
of the valve failing to open from the control room is a delay in the ability to place shutdown
cooling in service by the normal means. Because the valve is not able to function as
described in the
- UFS [[]]
AR, the system is degraded; however, there is no affect on the
safety-related function of the valve, which is to close automatically for containment
isolation.
The failure to identify during the 10 CFR 50.59 screening process for a procedure change
to N1-OP-04 that the change was not consistent with the Unit
- 1 UFS [[]]
AR is considered a
violation of minor significance. As such, this issue is not subject to enforcement action, in
accordance with the NRC's Enforcement Policy.
.4 Annual Sample - Unit 2 Operator Workarounds (One sample) a. Inspection Scope The inspectors reviewed the Unit 2 operator workarounds, operator burdens, and
operations items of interest, defeated annunciators, control room deficiencies, and open
operability determinations. The review focused on the reliability and availability of
mitigating systems with particular focus on issues that had the potential to affect the ability
of operators to respond to plant transients and events. Also, the inspectors reviewed the
governing procedure,
REL-02, "Control of Operator Workarounds, Burdens, and
Interests." The inspectors interviewed operations personnel on their knowledge of
selected workarounds and the associated compensatory actions. In addition, the
inspectors discussed with engineering and operations management the planned
corrective actions for restoration of some of the degraded systems.
24 b. Assessment and Observations No findings of significance were identified. None of the identified issues, individually or in the aggregate, appear to have a negative impact on the ability of the operators to
complete action in procedures, or to significantly affect the timeliness of those actions.
.5 Annual Sample: Review of
- NMP [[]]
NS Response to Generic Letter 2007-01 (One Sample)
a. Inspection Scope The inspectors selected CRs 2007-0895 and 2007-1977 as a problem identification and
resolution (PI&R) sample for a detailed follow-up review. CR 2007-0895 documented the
applicability and response to Generic Letter (GL) 2007-01, "Inaccessible or Underground
Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant
Transients." CR 2007-1977 documented water leaking into both the control and reactor
buildings from a Unit 2 Division 3 electrical raceway. The Unit 2 Division 3 electrical raceway supports the power cables from the Division 3 EDG in the control building to the
high pressure core spray (HPCS) pump in the reactor building. The inspectors reviewed
relevant CRs to ensure that issues associated with potentially submerged cables were
fully identified, appropriately evaluated, and corrective actions were specified and
prioritized to prevent recurrence. The inspectors discussed the issue with engineering
personnel and reviewed work orders, maintenance procedures, drawings and completed
surveillance and test procedures on the potential submerged cables.
b. Findings The inspectors inspected
GL and corrective actions taken to
resolve the potential adverse condition documented in CR 2007-1977. Specifically, on
April 1, 2007, a few months after receiving
NMPNS identified a condition
where water was leaking into both the control and reactor buildings indicating that the
NMPNS provided
the requested information in
NRC. GL 2007-01 informed licensees of an increase in inaccessible or underground cable
failure in the industry due to moisture-induced degradation. The GL discussed that
periodic draining may decrease the rate of cable insulation degradation, but would not
prevent cable failures. In addition, GL 2007-01 discussed that some licensees have
detected cable degradation prior to failures through techniques for measuring and
trending the condition of cable insulation. Although
- NMP [[]]
NS inspected and pumped down manholes every six months and tested the
insulation resistance to ground (megger) of some inaccessible/underground power cables
as part of the associated
- HP [[]]
- NMP [[]]
HPCS power cables were qualified for
submergence and have had no failures of underground cables at the site.
25The
power cables are very similar, if not identical to other power cables recently reviewed.
Based on the information provided by
HPCS power
cables are qualified to be submerged for the life of the plant. As a result, the submergence qualification of the
- HP [[]]
CS power cables was a potential
performance deficiency, in that
III requires that measures shall be established to ensure that applicable regulatory requirements and the
design basis are correctly translated into specifications, drawings, procedures, and instructions. This issue is an unresolved item pending
- NMP [[]]
NS providing documentation
that the
- HPCS cables were purchased, tested and evaluated to be qualified for submergence for the life of the plant and
OA3 Followup of Events and Notices of Enforcement Discretion (71153 - One sample)
.1 Manual Scram due to EPR Failure a. Inspection Scope On October 23 at about 9:00 p.m., Unit 1 operators began to observe small oscillations in
reactor pressure. They attempted to transfer pressure control from the electronic
pressure regulator (EPR) to the mechanical pressure regulator (MPR) in accordance with
N1-SOP-31.2, "Pressure Regulator Malfunctions;" however, the EPR would not
disengage. At 9:26 p.m., when the pressure oscillations had turned into a decreasing
trend in pressure, operators manually scrammed the reactor. Following the scram, reactor vessel water level shrank to 36 inches (an expected
response to a scram) and operators entered
RPV Control." The high pressure
coolant injection system initiated to restore normal water level. Following the main turbine
trip, all of the turbine bypass valves (TBVs) opened and remained open due to the
- MS [[]]
IVs at 9:28 p.m. Several
minutes later, the
MSIVs. A normal plant cooldown to cold
shutdown was then commenced using the TBVs. Cold shutdown conditions were
achieved on October 24 at 9:32 a.m. The inspectors responded to the control room and observed operators' responses to the
event. The inspectors verified that operators responded in accordance with the applicable
procedures. The inspectors confirmed that no emergency plan emergency action level
thresholds had been exceeded and that the event was appropriately reported to the NRC. The inspectors reviewed the circumstances surrounding the event. The inspectors
monitored troubleshooting activities and corrective actions through attendance of outage
update meetings, discussions with plant personnel, and review of records, including the
post-scram review.
26b. Findings No findings of significance were identified. 4OA5 Other Activities .1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope During the inspection period, the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with
- NMP [[]]
NS's
security procedures and regulatory requirements relating to nuclear plant security. These
observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors' normal plant status review and inspection activities.
b. Findings No findings of significance were identified.
.2 Temporary Instruction (TI) 2515/176 - Emergency Diesel Generator TS Surveillance Requirements Regarding Endurance and Margin Testing
a. Inspection Scope The objective of
EDG TS Surveillance Requirements Regarding Endurance
and Margin Testing," is to gather information to assess the adequacy of nuclear power
plant
TS. The
inspectors reviewed EDG ratings, design basis event load calculations, surveillance
testing requirements and EDG vendor specifications, and gathered information in
accordance with TI 2515/176.
The inspectors' assessment and information gathered while completing this TI was
discussed with licensee personnel. This information was forwarded to the Office of
Nuclear Reactor Regulation for further review and evaluation.
b. Findings
No findings of significance were identified. 4OA6 Meetings, including Exit Exit Meeting Summary
27 The inspectors presented the inspection results to Mr. Keith Polson and other members of
NMPNS acknowledged that no proprietary
information was involved.
- ATTACH [[]]
- MENT [[:]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- ATION [[]]
- KEY [[]]
- POINTS [[]]
- OF [[]]
CONTACT Licensee Personnel
K. Polson, Vice President
P. Bartolini, Supervisor, Mechanical Engineering
S. Belcher, Plant Manager
W. Byrne, Manager, Nuclear Security
MSPI Coordinator)
J. Kaminski, Manager, Emergency Preparedness
J. Krakuszeski, Manager, Operations
J. Laughlin, Manager, Engineering Services
C. Nielsen, Supervisor, Engineering
T. Shortell, Manager, Training
S. Sova, Manager, Radiation Protection
H. Strahley, Unit 2 General Supervisor Operations
T. Syrell, Director, Licensing
- LIST [[]]
- OF [[]]
- ITEMS [[]]
- AND [[]]
- DISCUS [[]]
SED Opened
HPCS Power Cables for
Submergence (Section 4OA2)
Opened and Closed 05000410/2008005-01
- LIST [[]]
- OF [[]]
- DOCUME [[]]
- NTS [[]]
- REVIEW [[]]
EPP-26, "Natural Hazard Preparation and Recovery," Revision 01
N1-OP-64, "Meteorological Monitoring," Revision 01
A-2N2-OP-102, "Meteorological Monitoring," Revision
- NRC [[]]
IE Bulletin No. 79-24, "Frozen Lines"
- NRC Information Notice 98-02, "Nuclear Power Plant Cold Weather Problems and Protective Measures" Section 1R04: Equipment Alignment N1-
OP-14, "Containment Spray System," Revision 04301
C-18012, "Reactor Containment Spray Raw Water System P&I Diagram," Revision 25
N2-OP-100A, Standby Diesel Generators," Revision 09
N2-VLU-01, "Walkdown Order Valve Lineup and Valve Operations," Revision 00, Attachment 100A, "N2-OP-100A Walkdown Valve Lineup" N2-OP-35, "Reactor Core Isolation Cooling," Revision 07
N2-VLU-01, "Walkdown Order Valve Lineup and Valve Operations," Revision 00, Attachment 35, "N2-OP-35 Walkdown Valve Lineup" Section 1R05: Fire Protection Unit
- 1 UFS [[]]
AR, Appendix 10A, "Fire Hazards Analysis"
Unit
- 2 UFS [[]]
- CM [[]]
EB 9.5-1"
Unit
- 2 UFS [[]]
AR, Appendix 9B, "Safe Shutdown Evaluation"
N2-FPI-PFP-0201, "Unit 2 Pre-Fire Plans," Revision 0
Section 1R11: Licensed Operator Requalification Program Quarterly Review N1-SOP-1.4, "Stuck Open ERV," Revision 01
N1-SOP-1, "Reactor Scram," Revision 01900
N1-EOP-2, "RPV Control," Revision 01400
N1-EOP-4, "Primary Containment Control," Revision 01400
N2-SOP-23, "EHC Pressure Regulator Failure," Revision 05
N2-SOP-08, "Unplanned Power Changes," Revision 05
N2-SOP-13, "Loss or Degraded CCP System," Revision 02
N2-SOP-101C, "Reactor Scram," Revision 03
N2-SOP-34, "Stuck Open Safety Relief Valve," Revision 04
N2-EOP-RPV, "RPV Control," Revision 01200
N2-EOP-PC, "Primary Containment Control," Revision 12
N2-EOP-C2, "RPV Blowdown," Revision 11
Biennial Review
TR-1.01-22, "License Operator Requalification Exam Writers Guide," Revision 00401
S102-CY0807OE Cycle 0807 Selected Operating Experience
Feedback Notebook -
TR-1.01-40, Attachment 4, "Evaluation Failure Action Plan," Revision 03
A-3NMP-TR-1.01-40, "Implementation Phase Activities," Revision
TR-1.01-1005, "Implementation Phase Activities," Revision 02
N2-215003-RBO-03 - Power Range Neutron Monitoring System & Rod Block Monitor
N2-242001-RBO-02 - Auxiliary Steam System
2102-CY0807C01E,
PIC122 Controller Training
S-SAF-16, "Schedule, Perform, Process, and Transmit Results for Physical Examinations on Licensed Reactor Operator and License Candidate," Revision 06 CR 2007-2380
CR 2006-545
CR 2007-5266
CR 2006-5646
Simulator Testing:
2007 Annual
- AN [[]]
SI Testing Real Time Test
Operating Limits Exceeded Test
Normal Operating Tests Steady State Tests
Transient Tests (10)
Reactivity Manipulation Certification
Scenario Based Testing: Control Rod Drive System
Reactor Recirculation System
Shutdown Cooling System
Plant Shutdown and Cooldown from Power Operations
Main Power Scenario
Emergency Cooling System
Emergency AC Distribution Scenario
N1-SOP-1 Reactor Scram
N1-SOP-31.1 Turbine Trip
NRC Scenario 1, 2/27/07
NRC Scenario 2, 2/27/07
NRC Scenario 3, 9/19/06
NRC Scenario 4, 2/27/07
Section 1R12: Maintenance Effectiveness S-MRM-REL-0101, "Maintenance Rule," Revision 18
S-MRM-REL-0104, "Maintenance Rule Scope," Revision 01
S-MRM-REL-0105, "Maintenance Rule Performance Criteria," Revision 01
Maintenance Rule Expert Panel Meeting Record, March 14, 2008
Unit
RCIC Maintenance Rule Scoping Document
A-4Section 1R13: Maintenance Risk Assessments and Emergent Work Control
PSH-03, "On-line Work Management Process," Revision 11
Section 1R15: Operability Evaluations
OP-1.01-1002, "Conduct of Operability Determinations / Functionality Assessments,"
Revision 00
N1-SOP-29.1, "EOP Key Parameter - Alternate Instrumentation," Revision 01
Section 1R18: Plant Modifications N2-08-059, "Instrument Air Header Hot Tap Blow Down Valve," Revision 00
Section 1R19: Post Maintenance Testing
SAT-02, "Pre/Post Maintenance Test Requirements," Revision 26
Section 1R20: Refueling and Other Outage Activities N1-OP-43C, "Plant Shutdown," Revision 02
N1-OP-4, "Shutdown Cooling System," Revision 02701
NMP Unit 1 Post Scram Review for scram 08-01 on October 23, 2008
N2-OP-101C, Plant Shutdown, Revision 18
N2-OP-31, Residual Heat Removal System, Revision 18
Shutdown Safety Review Report for Unit 2 Outage 2P801
OUT-01, "Shutdown Safety," Revision 02400
Section 1R22: Surveillance Testing
OPS-117, "Integrated Risk Management," Revision 14
Section
QPA Quarterly Reports: First Quarter 2008; Second Quarter 2008; Third Quarter 2008
QPA Assessment Reports: Radiation Protection Practices; Unit 2 Radiologically Controlled Area Egress; Radiography of the Unit 2 Stator Cooling Water System; Radiation
Protection Technician Training Program Effectiveness Quarterly Performance Review Report - Radiation Protection: March 2008; June 2008;
September 2008
A-5Snapshot Assessments High Radiation Area Barricades and Controls
Gaps to Excellence for High Radiation Control
Radiography Controls
RFO-11 Personnel Contamination Events
Documentation of the Radiation Protection Vertical Slice Presentation Section
QPA Assessment Report - Calibration of Unit 2 Main Control Room Ventilation Radiation Monitors
Self-Assessment FSA-2008-0036-07, Respiratory Protection, Calibration and Surveillances,
and Control of Radioactive Material, Sources, and Contaminations
Snapshot Assessments: Knowledge Transfer and Retention for Dosimetry; Documentation of
Air Sample Analysis during mid cycle outage 2F702 Section
PCP, Revision 7, 6/26/08 Unit 1 Radwaste PCP, Revision 8, 4/11/07
Focused Self Assessment 2007-26, "Radioactive Materials Shipping"
Mid-Cycle Focused Self-Assessment Report, August 20-24, 2007
- QPA ; 08-123]]
NS202RPT004Q01)," Revision 0
S202-CT0703C06, "2007 Cycle 3 Toolbox Training"
S202-CT0802C05, "Movement and Storage of RAM Refresher"
S202-CT0803C03, "Guidance for Loading Radioactive Equipment into Containers for Transport Offsite"
S000-49CFRS-QPA, "Function Specific Training for QPA"
Areva
CFR Part 50/61 Analysis Reports: 2006 Unit 2 Plant Smears; 2007 Unit 2 Plant Smears; 2006 Unit 2 Condenser Resins; 2007 Unit 2 Condenser Resins; 2006
Unit 1 Filter Sludge; 2007 Unit 1 Iron Prefilter; 2007 Unit 1 Cleanup Resin; 2007 Unit 1
Carbon; 2006 Unit
- 1 SS [[]]
CV; 2006 Unit 1 Condenser Resin; 2007 Unit 1 Condenser
Resin; 2006 Unit 1 Plant Smears; 2007 Unit 1 Plant Smears Radioactive Material Shipping Records: 08-1074; 08-1090; 08-1145; 08-2011; 08-2038 Section
- SC [[]]
RHR, and
- 1 MS [[]]
MSPI Basis Document," Revision 01
N2-OP-13, "Reactor Building Closed Loop Cooling System," Revision 07
- NRC [[]]
CFR 50.59 Screening Form for N1-OP-4, "Shutdown Cooling System"
CR 2004-3921
N1-OP-04, "Shutdown Cooling System," Revision 26
REL-02, "Control of Operator Workarounds, Burdens, and Interests," Revision 07
Nine Mile Point Performance Indicators for Operator Workaround Backlog, Control Room Deficiency Backlog, and Operations Compensatory Measure Backlog Unit 1 Control Room Deficiency and Defeated Annunciator Logs
Unit 1 Open Operability Determination Log
Unit 1 Operator Workaround / Burden / Items of Interest List
Unit 2 Control Room Deficiency Log
Unit 2 Open Operability Determination Log
Unit 2 Operator Workaround / Burden / Items of Interest List
Trend Review Second Quarter Performance Reviews for Work Management, Radiation Protection, Operations, Maintenance, Chemistry, and Training Third Quarter Performance Reviews for Chemistry, Engineering, Maintenance, and Radiation Protection
ECA-24, "Performance Improvement Process," Revision 01
Condition Reports 2007-0962 2007-5322
2007-7659
2007-7660
2007-7661
2007-7739
2008-2021
2008-2683
2008-4651
2008-8875
2008-8832
2008-8813
2008-8810
2008-8786 2008-8660 2008-8623
2008-7910
2008-7850
2008-7839
2008-7377
2008-7149
2008-7124
2008-6645
2008-6491
2008-6286
2008-5931
2008-5869
2008-5731 2008-5350 2008-4562
2008-4118
2008-6983
2008-3949
2008-3738
2008-3592
2008-3531
2008-3439
2008-3237
2008-2945
2008-2672
2008-2428
2008-2297
A-72008-2121 2008-2027
2008-1996
2008-1891
2008-1812
2008-1696
2008-1604
2008-1142
2008-1114
2008-0913
2008-0734
2008-0310
2008-9024
2008-4466
2008-4999
2008-0086
2008-0470
2008-1011 2008-1591 2008-1697
2008-1907
2008-2354
2008-2842
2008-3173
2008-3251
2008-3984
2008-4003
2008-4219
2008-4515
2008-4516
2008-5720
2008-6246
2008-6934
2008-7022
2008-8509
2008-5382 2008-6368 2008-8985
2008-8231
2008-8680
2008-8851
2008-8753
2008-8492
2008-8547
2008-7842
2008-7891
2008-7893
2008-7550
2008-8016
2008-8270
2008-5398
Section
KVACDGES, "Diesel Generator Loading (Unit 1)," Revision 06
E-32, "Diesel Generator Loading," Revision 12
Procedures N1-TTP-DGE-R01, "Diesel Generator Load Testing," Revision 02
N1-OP-45, "Emergency Diesel Generators," Revision 26
N1-ST-M4A, "Emergency Diesel Generator 102 and PB 102 Operability Test," Revision 02
N1-ST-M4B, "Emergency Diesel Generator 103 and PB 103 Operability Test," Revision 02
N1-ST-R2, "LOCA and EDG Simulated Auto Initiation Test," Revision 27
N1-SOP-33A.1, "Loss of 115KV," Revision 01
N2-OP-100A, "High Pressure Core Spray (HPCS) Diesel Generator," Revision 08
N2-OP-100B, "Standby Diesel Generators," Revision 09
N-2-OSP-EGS-R002, "Operating Cycle Diesel Generator 24 Hr Run and Load Rejection Test Division I and
OSP-EGS-R006, "Operating Cycle Diesel Generator 24 Hr Run and Load Rejection Test Division III," Revision 05
Completed Surveillances N1-TTP-DGE-R01, "Diesel Generator (102) Load Testing," Revision 02, dated 03/29/03
N1-TTP-DGE-R01, "Diesel Generator (102) Load Testing," Revision 02, dated 04/09/05
N1-TTP-DGE-R01, "Diesel Generator (102) Load Testing," Revision 02, dated 03/25/07
N1-TTP-DGE-R01, "Diesel Generator (103) Load Testing," Revision 01, dated 03/23/03
N1-TTP-DGE-R01, "Diesel Generator (103) Load Testing," Revision 02, dated 04/02/05
N1-TTP-DGE-R01, "Diesel Generator (103) Load Testing," Revision 02, dated 03/29/07
N-2-OSP-EGS-R002, "Operating Cycle Diesel Generator 24 Hr Run and Load Rejection
A-8Test Division I and
- II ) N-2-OSP-EGS-R002, "Operating Cycle Diesel Generator 24 Hr Run and Load Rejection Test Division I and
- II ) N-2-OSP-EGS-R002, "Operating Cycle Diesel Generator 24 Hr Run and Load Rejection Test Division I and
OSP-EGS-R006, "Operating Cycle Diesel Generator 24 Hr Run and Load Rejection Test Division III," Revision 05, dated 07/24/08
Drawings 3-N2.1-E21.2, "Elementary Wiring Diagram - 4.16 KV Emergency Power Boards & Diesel Generators #102 & #103," Revision 25
Other Documents
- SD [[]]
BD-804, "Emergency Diesel Generator System," Revision 04
N10197, Electromotive Division, Maintenance Instructions
N20395, "KSV Diesel Generator Instruction Manual," Revision 43
N20424, "Instruction Manual
- HP [[]]
CS Diesel Generator," Volumes 1 through 4, Revision 32
Unit
- 1 UFS [[]]
AR, Revision 20
Unit 1 & 2 Technical Specifications
Regulatory Guide 1.9, "Application and Testing of Safety-Related Diesel Generators in Nuclear
Power Plants," Revision 4
- IE [[]]
EE 387-1984, "Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations"
Attachment
- LIST [[]]
- OF [[]]
- ACRONY [[]]
- ADA [[]]
- ALA [[]]
RA as low as reasonably achievable
CAP corrective action program
CB control building
CFR Code of Federal Regulations
CR condition report
DBD design basis document
DOT Department of Transportation
EDG emergency diesel generator
EOP emergency operating procedure
EPR electronic pressure regulator
F Fahrenheit
IMC inspection manual chapter
kV kilovolt
LDE lens dose equivalent
- LO [[]]
- LP [[]]
- LP [[]]
CS low pressure core spray
MPR mechanical pressure regulator
mrem millirem
- MS [[]]
- MS [[]]
PI mitigating system performance indicator
NCV non-cited violation
- PA [[]]
RS Publicly Available Records
PI performance indicator
PI&R problem identification and resolution
PMT post maintenance test
qtr quarter
- RC [[]]
IC reactor core isolation cooling
R/hr rad per hour
RTP rated thermal power
SDE skin dose equivalent
SDP significance determination process
SOP special operating procedure
Attachment
- TE [[]]
DE total effective dose equivalent
TI temporary instruction
- UFS [[]]
AR updated final safety analysis report
URI unresolved item