IR 05000220/2014004
| ML14309A029 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, 07201036  |
| Issue date: | 11/04/2014 |
| From: | Daniel Schroeder Reactor Projects Branch 1 |
| To: | Costanzo C Exelon Generation Co |
| Schroeder D | |
| References | |
| IR 2014001, IR 2014004 | |
| Download: ML14309A029 (42) | |
Text
ber 4, 2014
SUBJECT:
NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2014004 AND 05000410/2014004 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) REPORT 07201036/2014001
Dear Mr. Costanzo:
On September 30, 2014, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station (NMPNS), Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on October 27, 2014, with Mr. Peter Orphanos, Plant Manager, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions 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 finding of very low safety significance (Green). The finding was determined not to involve a violation of NRC requirements. If you disagree with the cross-cutting aspect assignment or the finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at NMPNS. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69
Enclosure:
Inspection Report 05000220/2014004 and 05000410/2014004 and ISFSI Report 07201036/2014001 w/Attachment: Supplementary Information
REGION I==
Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69 Report Nos. 05000220/2014004 and 05000410/2014004 Licensee: Exelon Generation Company, LLC Facility: Nine Mile Point Nuclear Station Unit 1 and Unit 2 Location: Oswego, New York Dates: July 1, 2014, through September 30, 2014 Inspectors: K. Kolaczyk, Senior Resident Inspector E. Miller, Resident Inspector G. Stock, Resident Inspector E. Burket, Emergency Preparedness Inspector C. Graves, Health Physicist D. Lawyer, Health Physicist O. Masnyk-Bailey, Health Physicist Approved by: Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
IR 05000220/2014004, 05000410/2014004; 07/01/2014 - 09/30/2014; Nine Mile Point Nuclear
Station (NMPNS), Units 1 and 2; Follow-Up of Events and Notices of Enforcement Discretion.
This report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified one Green finding. The significance of most findings is indicated by their color (i.e., greater than Green, or Green,
White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of United States Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a Green finding (FIN) of CNG-PR-1.01-1005, Control of Technical Procedure Format and Content, Revision 00500, because Exelon Generation Company, LLC (Exelon) provided Unit 2 operators with an inadequate auxiliary boiler system operating procedure. Specifically, N2-OP-48, Auxiliary Boiler System, Revision 01100.00, did not provide operators adequate detail to properly establish chemistry requirements for water conductivity of the auxiliary boiler system. On March 23, 2014, when Unit 2 experienced a trip of the auxiliary boiler system due to inadequate water conductivity, operators became challenged with system restoration which caused an unplanned loss of secondary containment and entry into Technical Specification (TS) 3.6.4.1, Secondary Containment. Exelon generated condition report (CR)-2014-002281 regarding this issue.
Immediate corrective actions included updating chemistry requirements associated with auxiliary boiler procedures, implementing new preventive maintenance (PM) strategies for significant components associated with the auxiliary boilers, and implementing new performance monitoring plans.
This finding is more than minor because it affected the procedure quality attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, over the past 2 years, the auxiliary boilers have experienced trips as a result of insufficient procedural guidance. On March 23, 2014, the inadequate procedural guidance resulted in a trip and subsequent loss of reactor building (RB) differential pressure (DP). This caused an unplanned entry into the secondary containment emergency operating procedure and an unplanned entry into TS 3.6.4.1, which presented unnecessary challenges and distractions to operators during a planned down-power. In accordance with IMC 0609.04, Initial Characterization of Findings, the inspectors used IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, because secondary containment was declared inoperable following a loss of building heating. Using Appendix A, Exhibit 3, Barrier Integrity Screening Questions, Section C, Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building, the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency resulted in a trip of the auxiliary boiler system and a loss of secondary containment, the RB DP was restored to greater than 0.25 inches of water, within the allowable limiting condition for operation time, and did not result in a failure of the ability for secondary containment to maintain isolation or impact the ability for standby gas treatment system to maintain secondary containment. This finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety. Specifically, the inadequate management oversight of the auxiliary boilers resulted in numerous failures of the auxiliary boilers due to inadequate knowledge transfer, inaccurate classifications of maintenance rule functional failures for the system, inadequate procedures for boiler operation, and inadequate procedures for the prompt restoration of secondary containment when the auxiliary boiler system is not available [H.1].
(Section 4OA3)
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On September 13, 2014, operators reduced reactor power to 44 percent to perform a condenser tube leak repair, hydraulic control unit (HCU) repairs, control rod scram time testing, turbine stop valve and turbine control valve testing, and a rod pattern adjustment. Operators returned reactor power to 100 percent following maintenance and testing on September 14. On September 20, operators reduced reactor power to 80 percent for reactor recirculation motor generator 13 recovery and rod pattern adjustment. Unit 1 returned to 100 percent reactor power the same day and remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On August 12, 2014, operators reduced reactor power to 98 percent when the turbine bypass control system valves cycled open momentarily because of an intermittent electrical short in the electrohydraulic control system. Reactor power was returned to 100 percent on August 14. On September 6, operators reduced reactor power to 65 percent to perform a feedwater pump exchange, control rod scram time testing, and turbine stop valve and turbine control valve testing. Operators restored reactor power to 100 percent on September 7. On September 21, operators reduced reactor power to 98 percent due to a feedwater heater level control valve failure. Following repair, operators restored reactor power to 100 percent on September 22. Unit 2 remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
a. Inspection Scope
.1 Partial System Walkdowns
The inspectors performed partial walkdowns of the following systems:
Unit 1 emergency condenser system on July 2, 2014 Unit 2 Division I standby gas treatment system (SGTS) during Division II SGTS maintenance on July 28, 2014 Unit 1 emergency diesel generator (EDG) raw water during EDG 103 surveillance testing on August 4, 2014 Unit 2 Division II control room special filter system during Division I SGTS maintenance on August 12, 2014 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Review (UFSAR), TSs, work orders (WOs), CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
During the week of September 29, 2014, the inspectors performed a complete system walkdown of accessible portions of the Unit 1 diesel-driven fire pump and fire main system located in the screen house to verify the existing equipment lineup was correct.
The inspectors reviewed operating procedures, drawings, and the UFSAR to verify the system was aligned to perform its required functions. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure Exelon staff appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 6 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 1 battery board room 11 (fire area (FA) 16B) on July 7, 2014 Unit 1 battery board room 12 (FA 16A) on July 7, 2014 Unit 1 battery room 11 (FA 17B) on July 7, 2014 Unit 1 battery room 12 (FA 17A) on July 7, 2014 Unit 1 uninterrupted power supply (UPS) security battery room (FA 7) on July 10, 2014 Unit 2 Division lll diesel generator room (FA 30) on July 10, 2014
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, flooding calculations, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if Exelon personnel identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the Unit 1 RB track bay extension area, elevation 261, and toured the area on August 18 and 19, 2014, to verify the adequacy of equipment seals, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, and control circuits.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training (2 samples)
a. Inspection Scope
The inspectors observed:
Unit 2 job performance measure scenario, which involved restoration of suppression pool water level using high-pressure core spray on July 18, 2014 Unit 1 licensed operator simulator training, which included a failure of the automatic voltage regulator, a fault on power board 16B, and small break loss-of-coolant accident on July 22, 2014 The inspectors evaluated operator performance during the simulated event and verified completion of risk-significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the TS action statements entered by the shift manager.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
(2 samples)
a. Inspection Scope
The inspectors observed:
Unit 1 control room operations during power maneuver activities to support feedwater booster pump testing and shutdown of motor-driven feedwater pump 12 on July 9, 2014 Unit 2 control room operations during reactor core isolation cooling (RCIC)surveillance testing on August 7, 2014 The inspectors reviewed CNG-OP-1.01-1000, Conduct of Operations, Revision 01000, and verified that procedure use, crew communications, and coordination of plant activities among work groups similarly met established expectations and standards.
Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Unit 2 main control room and relay room temperature control valves 2HVK*TV21A, 2HVK*TV21B, 2HVK*TV22A, and 2HVK*TV22B on September 17, 2014 Unit 1 reactor pressure vessel head safety relief valves PSV-01-119A, PSV-01-119B, PSV-01-119C, PSV-01-119D, PSV-01-119F, PSV-01-119G, PSV-01-119H, PSV-01-119J, and PSV-01-119M on September 18, 2014 Unit 1 shutdown cooling pumps 11, 12, and 13 on September 19, 2014
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment from service. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Unit 1 unplanned maintenance of UPS162A following a blown fuse on July 1, 2014 Unit 2 electric-driven fire pump 2FPW-P2 during planned maintenance on diesel-driven fire pump 2FPW-P1 on July 16, 2014 Unit 1 planned maintenance on containment spray system 112 on July 24, 2014 Unit 1 planned maintenance on instrument air compressor 11 on August 19, 2014 Unit 1 unplanned isolation of control room emergency ventilation system during diagnostic testing of block valve 210.1-02 on September 10, 2014 Unit 1 planned maintenance of the main condenser for tube leak repairs, HCU repairs, and scram time testing on September 13, 2014 Unit 1 failure of a drywell high-pressure instrument calibration due to a calibration unit test box failure and use of alternate test method on September 17, 2014
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Unit 2 local power range monitor 56-33C causing average power range monitor #3 upscale high alarms on July 15, 2014 Unit 1 intermediate range monitor 15 being taken out of bypass on July 16, 2014 Unit 1 hot bearing on EDG 103 raw water pump on August 15, 2014 Unit 2 low pressure coolant injection operability during suppression pool cooling operation on September 3, 2014 Unit 2 Division II EDG elevated governor oil temperature on September 11, 2014 Unit 1 electromatic relief valve pilot solenoid actuator spring on September 29, 2014 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Exelons evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Engineering Change Package (ECP)-14-000677 - temporary modification to disable the Unit 2 electrohydraulic control stop valve load limit logic that renders the turbine bypass valves TS inoperable ECP-14-000736 - temporary modification to mitigate air leakage on unit 1 HCU-44-3031 scram valve pilot air header ECP-14-000748 - temporary modification to replace unit 2 SGTS pressure control valve 2GTS*PCV80A
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities 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 the information in the applicable licensing basis and/or design basis documents, 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 2 instrument air compressor 2IAS-C3A following mechanical PM on August 7, 2014 Unit 1 planned maintenance on core spray pump 121 circuit breaker on August 25, 2014 Unit 2 condensing water pump 2SWP*P2B following packing adjustment on August 25, 2014 Unit 2 containment atmosphere monitoring isolation valves 2CSM*SOV61B and 2CMS*SOV62B following time delay relay replacement on August 26, 2014 Unit 1 motor-driven fire pump strainer 100-22 following mechanical PM on August 28, 2014 Unit 2 spent fuel pool filter bypass valve 2SFC*FV113 following replacement on September 10, 2014 Unit 2 hydrogen recombiner outside isolation valve 2HCS*MOV1B following electrical PM on September 12, 2014 Unit 2 SGTS pneumatic supply/accumulator leak rate test following pressure control valve 2GTS*PV5A actuator replacement on September 21, 2014
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Unit 1, N1-ST-M4A, Emergency Diesel Generator 102 and PB 102 Operability Test on July 21, 2014 Unit 2, N2-OSP-EGS-M@002, Diesel Generator and Diesel Air Start Valve Operability Test, Division III on July 22, 2014 Unit 2, N2-OSP-SLS-Q001, Standby Liquid Control Pump, Check Valve, Relief Valve Operability Test and ASME XI Pressure Test on July 31, 2014 (inservice test)
Unit 1, N1-ST-M1A, Liquid Poison Pump 11 Operability Test on August 11, 2014 (inservice test)
Unit 1, N1-ST-Q3, HPCI [high pressure coolant injection] Pump and Check Valve Operability Test on August 14, 2014 (inservice test)
Unit 2, N2-CSP-SLS-@112, Adjustment of SLS Tank Sodium Pentaborate Concentration on August 27, 2014 Unit 1, N1-EPM-GEN-291, Generator Shaft Voltage Reading and Brush Inspection on September 8, 2014
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Exelon implemented various changes to NMPNS emergency action levels (EALs),emergency plan, and implementing procedures. In accordance with 10 CFR 50.54(q)(3),
Exelon determined that any changes made to the EALs, emergency plan, and its lower-tier implementing procedures did not result in any reduction in effectiveness of the plan and that the revised plan continued to meet the standards in 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.
The inspectors performed an in-office review of all EAL and emergency plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5) including the changes to lower-tier emergency plan implementing procedures to evaluate for any potential reductions in effectiveness of the emergency plan. This review by the inspectors was not documented in an NRC safety evaluation report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
During the period of July 21 to 24, 2014, the inspectors reviewed Exelons performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR 20, Standards for Protection Against Radiation; guidance in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas of Nuclear Plants, Revision 1; TSs; and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the 2013 performance indicators (PIs) for the Occupational Radiation Safety cornerstone, radiation protection program audits, and reports of operational occurrences related to occupational radiation safety since the last inspection.
Radiological Hazard Assessment The inspectors determined there have been no changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public.
The inspectors conducted walkdowns and independent radiation measurements including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions.
Instructions to Workers The inspectors assessed whether permissible dose for work under each radiation work permit (RWP) reviewed was clearly identified. The inspectors evaluated whether electronic personal dosimeter alarm set points were in conformance with survey material and radiological conditions.
Contamination and Radioactive Material Control The inspectors observed Unit 1 and Unit 2 access control points where Exelon monitors material leaving the radiologically controlled area and inspected the methods used for control, survey, and release of these materials from the control point. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with 10 CFR 20 requirements.
Radiological Hazards Control and Work Coverage The inspectors evaluated radiological conditions and performed independent radiation measurements during walkdowns and assessed whether the conditions were consistent with postings, surveys, RWPs, and worker briefings.
The inspectors evaluated the adequacy of radiological controls, surveys, and radiation protection job coverage, and evaluated Exelons use of electronic personal dosimeters in high noise areas.
The inspectors reviewed the application of dosimetry to monitor exposure to personnel in high radiation work areas with significant dose rate gradients.
The inspectors examined Exelons programmatic controls for storage of highly activated or contaminated components.
Radiation Worker Performance The inspectors observed the performance of radiation workers with respect to radiation protection requirements and assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place.
Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in Exelons CAP. The inspectors assessed Exelons process for applying operating experience to their plant.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
During the period of July 21 to 24, 2014, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR 20; RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants Will Be As Low As Is Reasonably Achievable, Revision 3; RG 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable, Revision 1-R; TSs; and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed pertinent information regarding Unit 2 collective dose history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges during the last refueling outage (N2R14).
The inspectors compared the site-specific trends in collective exposures against the industry-average values, exposure values from similar vintage reactors, and the trend in average contact dose rates with recirculation piping measured on April 5, 2014.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities.
Radiological Work Planning The inspectors selected and reviewed the following high-exposure work activities:
Drywell operations activities Drywell valve and piping replacement/repairs Under-vessel work control rod drive and local power range monitor replacement Reactor disassembly/reassembly and cavity decontamination Refuel floor underwater activities The inspectors reviewed the ALARA work activity evaluations, exposure estimates, exposure reduction requirements, and post-work evaluations. The inspectors reviewed the grouping of radiological work into work activities based on historical precedence and industry standards.
Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the current annual collective dose estimate for accuracy and reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and for department and station collective dose goals.
The inspectors evaluated whether Exelon had established measures to track, trend, and reduce occupational doses for ongoing work activities and assessed whether dose threshold criteria were established for work-in-progress reviews. The inspectors evaluated the method used for adjusting exposure estimates or re-planning work when unexpected changes in scope or emergent work were encountered.
Source-Term Reduction and Control The inspectors reviewed Exelons records to determine the historical trends and current status of plant source term and assessed whether Exelon had developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.
Radiation Worker Performance The inspectors observed radiation worker and radiation protection technician performance during work activities being performed in radiation areas, airborne radioactivity areas, and high radiation areas and evaluated whether workers demonstrated the ALARA philosophy in practice and whether there were any procedural compliance issues.
Problem Identification and Resolution The inspectors evaluated whether problems associated with ALARA planning and controls were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in Exelons CAP. The inspectors assessed Exelons process for applying operating experience to their plant.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
During the period of August 11 to 14, 2014, the inspectors verified that gaseous and liquid effluent processing systems were maintained so radiological discharges were properly reduced, monitored, and released. The inspectors also verified the accuracy of the calculations for effluent releases and public doses.
The inspectors used the requirements in 10 CFR 20; 10 CFR 50 Appendix A, General Design Criteria for Nuclear Power Plants, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases; 10 CFR 50 Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low As Is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 10 CFR 50.35(a); 10 CFR 50.75(g); Title 40 of the CFR (40 CFR) 141, Maximum Contaminant Levels for Radionuclides; 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I, Revision 1; RG 1.21, Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste, Revision 2; RG 4.1, Radiological Environmental Monitoring for Nuclear Power Plants, Revision 2; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination) -- Effluent Streams and the Environment, Revision 2; NUREG-1302, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors; TSs; applicable industry standards; and Exelon procedures required by TSs/offsite dose calculation manual (ODCM) as criteria for determining compliance.
Event Report and Effluent Report Reviews The inspectors reviewed anomalous results, unexpected trends, abnormal releases, and radioactive effluent monitor operability issues that were identified and determined if these effluent results were evaluated, were entered in the CAP, and were adequately resolved.
ODCM and UFSAR The inspectors reviewed UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths to identify system design features and required functions. The inspectors reviewed changes to the ODCM made since the last inspection. When differences were identified, the inspectors reviewed the technical basis or evaluations of any changes. The inspectors reviewed documentation to determine if any non-radioactive systems that have become contaminated were disclosed either through an event report or the ODCM.
Groundwater Protection Initiative (GPI) Program The inspectors reviewed reported groundwater monitoring results and changes to Exelons written program for identifying and controlling contaminated spills/leaks to groundwater.
Procedures, Special Reports, and Other Documents The inspectors reviewed licensee event reports (LERs), event reports, and special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.
The inspectors reviewed effluent program implementing procedures including those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations. The inspectors reviewed copies of self-assessments and third party evaluation reports for the effluent monitoring program since the last inspection.
Walkdowns and Observations The inspectors walked down Unit 1 and Unit 2 radiation monitors and components of the gaseous and liquid discharge systems to verify that equipment configuration and flow paths aligned with the descriptions in the UFSAR and to assess equipment material condition. The review included potential unmonitored release points, building alterations which could impact airborne or liquid effluent controls, and ventilation system leakage that communicates directly with the environment.
The inspectors reviewed effluent system material condition surveillance records for equipment and areas associated with the systems that were not readily accessible due to radiological conditions. The inspectors walked down filtered ventilation systems to verify there were no degraded conditions associated with high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system.
The inspectors observed portions of the routine processing and discharge of radioactive gaseous effluent systems to verify that appropriate treatment equipment was used and the processing activities aligned with discharge permits.
The inspectors determined that Exelon had not made any changes to their effluent release paths since the last inspection. The inspectors discussed routine processing and discharge of liquid waste. The inspectors verified that appropriate effluent treatment equipment was used and that radioactive liquid waste was being processed and discharged in accordance with procedures and verified that no liquid discharges had taken place since the last inspection.
Sampling and Analysis The inspectors selected three gaseous effluent sampling activities from Unit 1 and Unit 2 and assessed the adequacy of controls to ensure representative samples were obtained.
The inspectors selected two gaseous effluent discharges made from Unit 2 with inoperable effluent radiation monitors to verify that controls were in place to ensure compensatory sampling was performed as required and that those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents. The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance based on the frequency of compensatory sampling since the last inspection.
The inspectors reviewed the results of the inter-laboratory and intra-laboratory comparison program to verify the quality of the radioactive effluent sample analyses.
The inspectors also assessed whether the laboratory comparison program included hard-to-detect isotopes.
Effluent Flow Measuring Instruments The inspectors reviewed the methodology used to determine the effluent stack and vent flow rates to verify that the flow rates were consistent with TSs, ODCM, and UFSAR values. The inspectors reviewed the differences between assumed and actual stack and vent flow rates to ensure that public dose calculations were not affected.
Air Cleaning Systems The inspectors assessed surveillance test results for TS-required ventilation effluent discharge systems using TS acceptance criteria.
Dose Calculations The inspectors reviewed all significant changes in reported dose values compared to the previous radioactive effluent release report to evaluate the factors which resulted in the change.
The inspectors reviewed three radioactive liquid and gaseous waste discharge permits to verify that the projected doses to members of the public were accurate and based on representative samples of the discharge path.
The inspectors evaluated the methods used to ensure that all radionuclides in the effluent stream were included within detectability limitations. The review included the current waste stream analyses to ensure hard-to-detect radionuclides were included in the effluent releases.
The inspectors reviewed changes in methodology for offsite dose calculations since the last inspection to verify the changes were consistent with requirements. The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to ensure appropriate dispersion/deposition factors were being used for public dose calculations.
The inspectors reviewed the latest land-use census to verify changes that affect public dose pathways had been factored into the dose calculations and environmental sampling and analysis program.
The inspectors evaluated whether the calculated doses were within the 10 CFR 50 Appendix I and TS dose criteria.
The inspectors reviewed records of any abnormal gaseous or liquid tank discharges to ensure the abnormal discharge were monitored by the discharge point effluent monitor.
Discharges made with inoperable effluent radiation monitors or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to account for the effluent release and were included in the calculated doses to the public.
GPI Implementation The inspectors reviewed monitoring results of the voluntary Nuclear Energy Institute (NEI) GPI to determine if Exelon had implemented the GPI as intended.
The inspectors reviewed identified leakage or spill events and entries made into Exelons decommissioning files. The inspectors reviewed evaluations of leaks or spills, and reviewed the effectiveness of any remediation actions. The inspectors reviewed onsite contamination events involving contaminated groundwater and assessed whether the source of the leak or spill was identified and isolated/terminated.
For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material discharged by assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and by assessing whether a survey/evaluation had been performed and determining whether Exelon completed offsite notifications as provided in its GPI implementing procedures.
Problem Identification and Resolution The inspectors assessed whether problems associated with the effluent monitoring and control program were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the CAP. In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Safety System Functional Failures (2 samples)
a. Inspection Scope
The inspectors sampled Exelons submittals for the safety system functional failures (MS05) PI for Unit 1 and Unit 2 for the period of July 1, 2013, through June 30, 2014. To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3. The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index (10 samples)
a. Inspection Scope
The inspectors reviewed Exelons submittal of the mitigating systems performance index for the following systems for the period of July 1, 2013, through June 30, 2014:
Unit 1 and Unit 2 Emergency Alternating Current Power System (MS06)
High-Pressure Injection System (MS07)
Heat Removal System (MS08)
Residual Heat Removal System (MS09)
Cooling Water System (MS10)
To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in NEI 99-02, Revision 7. The inspectors reviewed Exelons operator narrative logs, CRs, mitigating systems performance index basis document, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.3 Radiological Effluent TS/ODCM Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
During the period of August 11 to 14, 2014, the inspectors sampled Exelons submittals for the radiological effluent TS/ODCM radiological effluent occurrences (PR01) PI for the period of January 1, 2013, through June 30, 2014. The inspectors used PI definitions and guidance contained in NEI 99-02, Revision 7, to determine if the PI data was reported properly during this period.
The inspectors reviewed Exelons corrective action report database and selected individual reports generated to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated offsite dose calculations for the selected dates to determine if indicator results were accurately reported. The inspectors also reviewed Exelon staffs methods for quantifying gaseous and liquid effluents and determining effluent dose.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Review of the Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in procedure OP-AA-102-103, Operator Work-Around Program, Revision 004.
The inspectors reviewed Exelons process to identify, prioritize, and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent Exelon self-assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.
b. Findings and Observations
No findings were identified.
The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.
The inspectors also verified that Exelon entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, issued October 28, 2011, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the event to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.
Unit 2 rapid power reduction to 98 percent when the turbine bypass control system valves cycled open momentarily because of an intermittent electrical short in the electrohydraulic control system on August 12, 2014.
b. Findings
No findings were identified.
.2 LER 05000410/2014-006-00: Secondary Containment Inoperability Following Auxiliary
Boiler Trip On March 24, 2014, during a power reduction to support the start of a refueling and maintenance outage, Unit 2 experienced reduced DP between the RB (i.e. secondary containment) and the outside atmosphere. The reduced DP was caused by a loss of RB heating when the auxiliary boiler system tripped. The reduced DP also caused an unplanned entry into TS 3.6.4.1, Secondary Containment, which requires RB DP to be greater than or equal to 0.25 inches of vacuum water gauge. The RB DP also went positive, which resulted in entry into emergency operating procedure, N2-EOP-SC, Secondary Containment Control - Flowchart, Revision 01100.00. Operators were able to restore RB DP within 3 minutes of the start of the event. Exelon entered this issue into their CAP as CR-2014-002281 and performed an apparent cause evaluation.
Exelon attributed the cause of the loss of RB DP to inadequate oversight of the Unit 2 auxiliary boiler system and that less than adequate maintenance resulted in poor system reliability. Corrective actions associated with this issue included implementing new PM strategies on the auxiliary boilers, implementing new performance monitoring plans for the auxiliary boilers, and enhancing operating procedures to include more specific chemistry requirements. The enforcement aspects regarding Unit 2 auxiliary boiler performance and the loss of secondary containment are discussed below. This LER is closed.
b. Findings
Introduction.
The inspectors identified a Green FIN of CNG-PR-1.01-1005, Control of Technical Procedure Format and Content, Revision 00500, because Exelon provided Unit 2 operators with an inadequate auxiliary boiler system operating procedure.
Specifically, N2-OP-48, Auxiliary Boiler System, Revision 01100.00, did not provide operators adequate detail to properly establish chemistry requirements for water conductivity of the auxiliary boiler system. As a result, on March 23, 2014, when Unit 2 experienced a trip of the auxiliary boiler system due to inadequate water conductivity, operators were unable to restart the boiler, which caused an unplanned loss of secondary containment and entry into TS 3.6.4.1, Secondary Containment.
Description.
The auxiliary boiler system at Unit 2 produces low-pressure steam for support system operation when normal steam sources (main steam or extraction steam)are not available to support plant operation. The clean steam produced by the boilers provides heating to the RB. The auxiliary boiler consists of two high-voltage electrode-type boilers, which generate steam by resistance heating of the boiler water. Boiler function depends on flow rate of water to the electrodes and water conductivity.
Between 2012 and 2014, on several occasions, operators have not properly operated the auxiliary boiler system. For example, on April 5, 2012, operators did not have proper guidance to ensure successful operation of the A auxiliary boiler system resulting in a trip of auxiliary boiler. This issue was captured in CR-2012-002694. On September 12, 2012, operators experienced issues with the immersion heater supply breaker causing unavailability of the B auxiliary boiler. This issue was captured in CR-2012-008467.
On November 12, 2012, improper operating procedures associated with water chemistry control of the B auxiliary boiler led to a trip of boiler. This issue was captured in CR-2012-010349. On November 19, 2012, the A auxiliary boiler also tripped due to improper water chemistry. This issue was captured in CR-2012-010572. On March 9, 2014, the B auxiliary boiler tripped due to high-ground current as a result of improper chemistry controls. This issue was captured in CR-2014-001923. Each of these events illustrated operational challenges associated with the auxiliary boiler system.
On March 23, 2014, Unit 2 performed a down-power to begin a refueling outage. As part of the Unit 2 shutdown, operators were performing a primary containment purge to remove nitrogen and prepare the drywell atmosphere for personnel access to conduct maintenance and inspection activities. At 11:06 p.m., auxiliary boiler B tripped due to the load control valve failing to maintain auxiliary boiler pressure automatically.
Operators started auxiliary boiler A at 11:03 p.m. due to the issues being experienced with auxiliary boiler B. At 11:29 p.m., auxiliary boiler A tripped on high-ground current due to improper boiler water conductivity. Operators were unable to restore the auxiliary boilers due to chemistry requirements for water conductivity not being met. Without the auxiliary boilers, RB DP began to decrease due to the loss of building heating. At 12:01 a.m., operators began to stop the drywell purge which was using SGTS B at the time.
At 12:29 a.m., operators isolated the RB as DP reached the TS limit of 0.25 inches of vacuum water gauge. Operator actions were not timely enough to ensure RB DP was maintained, and subsequently, at 12:31 a.m., RB DP became less than 0.25 inches of water resulting in an unplanned entry into the limiting condition for operation (LCO) for TS 3.6.4.1, Secondary Containment, that requires RB DP to be greater than or equal to 0.25 inches of vacuum water gauge within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. It also resulted in an unplanned emergency operating procedure entry for positive DP in secondary containment. At 12:34 a.m., operators restored secondary containment using SGTS and exited TS 3.6.4.1.
Exelons apparent cause evaluation (CR-2014-002281) identified a number of issues associated with the auxiliary boiler system and operator performance. Exelon determined the apparent cause to be management and oversight of the auxiliary boiler operation and maintenance to be less than adequate resulting in poor reliability due to hardware deficiencies and inadvertent ground fault trips. Differences identified between the chemistry and operations procedures emphasized the challenges being given to operators. The operations procedure did not contain the level of detail that the chemistry procedure provided for maintaining boiler water conductivity. Exelon also discovered that although the load control valves were classified as significant per NMPNS AP-913, Equipment Reliability Program, there were no active PM activities being performed.
Immediate corrective actions included implementing new PM strategies for significant components associated with the auxiliary boilers, implementing new performance monitoring plans, and updating chemistry requirements associated with auxiliary boiler procedures.
While reviewing historical boiler performance, the inspectors also discovered three different failures in CR-2012-002694, CR-2012-008467, and CR-2012-010349 of the auxiliary boiler system within the past 2 years that were not properly classified as maintenance rule functional failures. Exelon generated CR-2014-005295 to document the inspectors concerns and performed a maintenance rule re-evaluation of the auxiliary boiler failures as part of corrective actions. Inspectors also determined that operators did not take timely actions to restore RB DP following a loss of the auxiliary boilers on March 23, 2014. Exelon generated CR-2014-006973 to document this issue and developed a corrective action to enhance procedure N2-OP-52, Reactor Building Ventilation, Revision 01100.00, with an off-normal section that will start SGTS in an accelerated manner when RB DP is inadequate.
Analysis.
The inspectors determined Exelons failure to provide an adequate procedure to operate the auxiliary boiler system as required by CNG-PR-1.01-1005, Control of Technical Procedure Format and Content, was a performance deficiency that was reasonably within their ability to foresee and correct and should have been prevented.
This finding is more than minor because it affected the procedure quality attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, over the past 2 years, the auxiliary boilers have experienced trips as a result of poor procedural guidance. On March 23, 2014, the poor procedural guidance of the auxiliary boilers resulted in a trip and subsequent loss of RB DP. This caused an unplanned entry into the secondary containment emergency operating procedure and an unplanned entry into the LCO for TS 3.6.4.1 which presented unnecessary challenges and distractions to operators during a planned down-power.
In accordance with IMC 0609.04, Initial Characterization of Findings, issued June 19, 2012, the inspectors used IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, because secondary containment was declared inoperable following a loss of building heating. Using Appendix A, Exhibit 3, Barrier Integrity Screening Questions, Section C, Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building, the inspectors determined that this finding is of very low safety significance (Green) because the finding only represents a degradation of the radiological barrier function provided for the control room, or auxiliary building, spent fuel pool, or SBGT system (boiling water reactor).
This finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety. Specifically, the inadequate management oversight of the auxiliary boilers resulted in numerous failures of the auxiliary boilers due to inadequate knowledge transfer, inaccurate classifications of maintenance rule functional failures for the system, inadequate procedures for boiler operation, and inadequate procedures for the prompt restoration of secondary containment when the auxiliary boiler system is not available [H.1].
Enforcement.
This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The inspectors determined that the finding did not represent a non-compliance issue because CNG-PR-1.01-1005, Control of Technical Procedure Format and Content, Revision 00500, is not a procedure recommended by USNRC Regulatory Guide 1.33, Quality Assurance Program Requirements, Appendix A, Typical procedures for Pressurized Water Reactors and Boiling Water Reactors, or Nine Mile Point Unit 2 TS 5.4.1. Because this finding does not involve a violation and it is of very low safety significance (Green), it is identified as a FIN. (FIN 5000410/2014004-01, Loss of Secondary Containment due to Loss of Auxiliary Boiler System)
4OA5 Other Activities
Operation of an Independent Spent Fuel Storage Installation (ISFSI) at Operating Plants (60855 and 60855.1)
a. Inspection Scope
During the period of August 4 to 7, 2014, the inspectors observed and evaluated Exelons loading of a dry shielded canister (DSC) associated with Exelons current ISFSI dry cask campaign at Unit 1. The inspectors also reviewed Exelons activities related to long-term operation and monitoring of the ISFSI. The inspectors verified compliance with the certificate of compliance, TSs, regulations, and Exelons procedures.
The inspectors observed and evaluated Exelons loading of the third 61BTH canister associated with Exelons current ISFSI dry cask loading campaign. The inspectors observed cask processing operations including moving the transfer cask (with the DSC inside) from the pool to the cask preparation area, surveying for contamination and dose rates, blow-down, vacuum drying, helium backfilling, welding operations, visual tests, dye penetrant tests, and helium leak tests. The inspectors also observed the transfer cask/DSC alignment with the horizontal storage module and insertion of the DSC into the horizontal storage module. During performance of these activities, the inspectors evaluated Exelons familiarity with procedures, supervisory oversight and communication, and coordination between the personnel involved. The inspectors attended station briefings to assess Exelons ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors.
The inspectors also reviewed loading and monitoring procedures and evaluated Exelons adherence to these procedures.
The inspectors reviewed Exelons program associated with fuel characterization and selection for storage. The inspectors reviewed cask fuel selection packages to verify that Exelon was loading fuel in accordance with the certificate of compliance and TS. In addition, the inspectors independently verified the cask loading via review of the digital recording.
The inspectors reviewed radiation protection procedures and RWPs associated with the ISFSI loading campaign. The inspectors also reviewed the ALARA goal for the cask loading to determine the adequacy of Exelons radiological controls and to ensure that radiation worker doses were ALARA and that project dose goals could be achieved. The inspectors reviewed radiological survey records from the current loading campaign to confirm that dose rate levels measured on the cask were consistent with values specified in the UFSAR.
The inspectors performed tours of the heavy haul path and ISFSI pad to assess the material condition of the path, pad, and the loaded horizontal storage modules and verified that Exelon appropriately performed surveillances in accordance with TS requirements. The inspectors verified that transient combustibles were not being stored on the ISFSI pad or in the vicinity of the loaded casks. Environmental reports were reviewed to verify that areas around the ISFSI site boundary were within the limits specified in 10 CFR 20 and 10 CFR 72.104. The inspectors confirmed that vehicle entry onto the ISFSI pad was controlled in accordance with Exelons procedures.
The inspectors reviewed Exelons 10 CFR 72.48 screenings to verify that Exelon had appropriately considered the conditions under which they may make changes without prior NRC approval. The inspectors reviewed revisions to the 10 CFR 72.212 report.
The inspectors also reviewed corrective action reports, audit reports, and self-assessments that were generated since Exelons last loading campaign to ensure that issues were being properly identified, prioritized, and evaluated commensurate with their safety significance.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On October 27, 2014, the inspectors presented the inspection results to Mr. Peter Orphanos, Plant Manager, and other members of the NMPNS staff. The inspectors verified that no propriety information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- C. Costanzo, Site Vice President
- P. Orphanos, Plant Manager
- M. Busch, Assistant Operations Director of Operations
- K. Clark, Director of Security
- J. Dean, Supervisor, Manager, Nuclear Oversight
- S. Eckhard, Manager, Engineering
- M. Khan, Senior Manager, Engineering
- M. Kunzwiler, Manager, Site Security Operations
- D. Moore, Director of Regulatory Assurance
- T. Tanguay, Unit 2 Shift Operations Superintendent
- W. Trafton, Director of Operations
- J. Thompson, General Supervisor, Mechanical Maintenance
- J. Tsardakas, Unit 1 Shift Operations Superintendent
- B. Scaglione, Manager, Engineering
- M. Shanbhag, Licensing Engineer
- A. Sterio, Director of Site Maintenance
- P. Swift, Director of Engineering
- E. Zumwalt, Senior Engineer, Engineering
- T. Syrell, Director of Regulatory Assurance
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000410/2014004-01 FIN Loss of Secondary Containment due to Loss of Auxiliary Boiler System (Section 4OA3.2)
Closed
- 05000410/2014-006-00 LER Secondary Containment Inoperability Following Auxiliary Boiler Trip (Section 4OA3.2)