IR 05000333/2011004

IR 05000333-11-004, on 07/01.2011 - 09/30/2011, for James A. Fitzpatrick

ML11313A056
Person / Time
Site:	FitzPatrick
Issue date:	11/08/2011
From:	Gray M K Reactor Projects Branch 2
To:	Michael Colomb Entergy Nuclear Northeast
Mel Gray
References
IR-11-004
Download: ML11313A056 (38)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406.1415 November 8, zOLl Mr. Mike Colomb Site Vice President Entergy Nuclear Northeast James A. FitzPatrick Nuclear Power Plant P. O. Box 110 Lycoming, NY 13093

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED I NSPECTION REPORT 05000333/201 1004

Dear Mr. Colomb:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick).

The enclosed inspection report documents the inspection results which were discussed on October 19, 2011, with Mr. Brian R. Sullivan and other members of your staff.The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section Vl.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. lf you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis ior your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident lnspector at FitzPatrick. ln accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter and 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 Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/st l //rurt ,/rl ^*7 Mel Gray, Chief (Projects Branch 2 Division of Reactor Projects Docket No.: 50-333 License No.: DPR-59

Enclosure:

Inspection Report05000333/20110Q4

w/Attachment:

Supplemental I nformation cc Mencl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500033312011004;07lQ112011 - 0913012011;

James A. FitzPatrick Nuclear Power Plant;Routine Resident Integrated Report.The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006,

Other Findings

A violation of very low safety significance that was identified by Entergy personnel was reviewed by the inspectors.

Corrective actions taken or planned by Entergy personnel have been entered into Entergy's corrective action program (CAP). This violation and corrective action tracking number are listed in Section 4OA7 of this report.Enclosure 4

REPORT DETAILS

Summarv of Plant Status The James A. FitzPatrick Nuclear Power Plant (FitzPatrick)began the inspection period operating at 100 percent reactor power. On September 28, 2011, power was reduced to 65 percent to perform a control rod sequence exchange, single control rod scram time testing and blade interference monitoring, main condenser water box back washing, and turbine valve testing. Operators restored power to 100 percent the following day. The plant continued to operate at or near full power for the remainder of the inspection period.1. REACTORSAFETY Gornerstones:

lnitiating Events, Mitigating Systems, and Barrier lntegrity 1R01 Adverse Weather Protection (71111.01 - 1 sample)a. lnspection Scope The inspectors reviewed FitzPatrick personnel's preparations in accordance with AOP-13, "High Winds, Hurricanes and Tornadoes," Revision 13, for potential high wind and heavy rain conditions associated with Hurricane lrene on August 28,2011. The inspectors reviewed the operating status of the reactor, reviewed the procedural limits and actions associated with high winds and hurricanes, and walked down accessible areas of the reactor building (RB) and turbine building (TB) to assess vulnerabilities to high winds and heavy rains. Walkdowns were also conducted in the emergency diesel generator (EDG), emergency service water (ESW), and screenhouse rooms. The inspectors reviewed conditions following the occurrence of the adverse weather to assess its impact. Documents reviewed for each section of this inspection report are listed in the Attachment.

These activities constituted one impending adverse weather conditions inspection sample.b. Findinqs No findings were identified.

1R04 Equipment

Aliqnment (71111.04)

.1 Quarterlv

Partial Svstem Walkdown (71111.04Q - 3 samples)a. Inspection Scope The inspectors performed three partial system walkdowns to verify the operability of redundant or diverse trains and components during periods of system train unavailability or following periods of maintenance.

The inspectors referenced system procedures, the updated final safety analysis report (UFSAR), and system drawings in order to verify the alignment of the available train was proper to support its required safety functions.

The i i Enclosure 5 inspectors also reviewed applicable condition reports (CRs) and work orders (WOs) to ensure that FitzPatrick personnel identified and properly addressed equipment discrepancies that could impair the capability of the available equipment train, as required by Title 10, Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVl, "Corrective Action." The inspectors performed a partial walkdown of the following systems:. 'A' residual heat removal (RHR) system when the'B' RHR system was out of service for testing;. Diesel engine driven fire pump 76P-1 upon completion of post maintenance testing (PMT); and o 'A' core spray system while the 'B' core spray system was out of service for testing.These activities constituted three partial system walkdown inspection samples.b. Findinqs No findings were identified.

1R05 Fire Protection

(71111.05)

.1 Quarterlv

Review (71111.05Q - 5 samples)a. Inspection Scope The inspectors conducted inspections of fire areas to assess the material condition and operational status of fire protection features.

The inspectors verified, consistentwith applicable administrative procedures, that combustibles and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and suppression and detection equipment were appropriately maintained; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with FitzPatrick's fire protection program. The inspectors evaluated the fire protection program for conformance with the requirements of license condition 2.C(3), "Fire Protection." o East switchgear room, fire arealzone ll/SW-2;o West switchgear room, fire arealzone lClSW-1;. 'A' and 'C' EDG rooms and switchgear room, fire arealzone V/EG-1 , EG-2, EG-5;. East crescent area, fire arealzone XVll/RB-1 E; and r North safety related pump room, fire arealzone Xltl/SP-2.

These activities constituted five quarterly fire protection inspection samples.b. Findinos No findings were identified.

6 1R06 Flood Protection Measures (71111.06 - 1 sample)a. lnspection Scope The inspectors examined manhole MH-7A in the 115 kilovolt (kV) switchyard, and MH-5A by main transformer T1A, during FitzPatrick personnel's annual inspection of yard manholes performed under WO 52285065-01.

These manholes contain non-safety class electrical cables that could affect the reliability of 1 15 kV offsite power. The inspectors also examined the condensate storage tank (CST) pit, which contains safety class instrument cables. The inspectors verified that cable insulation was not degraded and that cable support structures were adequate to maintain the integrity of the cables.The inspectors observed that the manholes were equipped with floatactuated sump pumps, but that there were no level indicators or alarms to alert operators to a pump failure. The inspectors noted that CR-JAF-2011-04407 documented sump pump issues that had been identified during the annual inspection, including excessive water accumulation in one manhole due to a stuck float actuator, and a failed sump pump in MH-7A. These conditions did not constitute violations of regulatory requirements because the affected manholes did not contain safety class electrical cables. The inspectors also noted that the CST pit is checked during daily operator rounds and therefore that the safety related cables were not likely to become submerged due to similar sump float issues.These activities constituted one underground bunker/manhole inspection sample.b. Findinqs No findings were identified.

1R07 Heat Sink Performance

(71111.Q7 - 1 sample)a. Inspection Scope The inspectors reviewed the ESW system annual thermal performance test that was performed on April 27,2011 in accordance with ST-8Q, "Testing of the Emergency Service Water System (lST)," Revision 41. This test determines the maximum lake temperature at which individual unit coolers in the east and west electric bays, and east and west crescents, can be considered operable.

Results that are less than the TS maximum allowable service water inlet temperature of 85 degrees Fahrenheit

('F) limit the plant's ability to operate under conditions of elevated lake temperature until the unit cooler degradation is corrected.

The inspectors noted that the operability of one unit cooler, 67UC-168, was limited to 84'F service water inlet temperature.

The inspectors verified that actual lake temperature had not exceeded this value during the summer season.These activities constituted one heat sink performance inspection sample.b. Findinqs No findings were identified.

7 1R1 1 Licensed Operator Requalification Proqram (71111.11Q - 1 sample)a. Inspection Scope On September 12, 2011, the inspectors observed licensed operator simulator training to assess operator performance during a scenario to verify that crew performance was adequate and evaluators were identifying and documenting crew performance problems.The inspectors evaluated the performance of risk significant operator actions, including the use of emergency operating procedures.

The inspectors assessed the clarity and effectiveness of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operation and manipulation, and the oversight and direction provided by the shift manager. Licensed operator training was evaluated for conformance with the requirements of 10 CFR Part 55, "Operators' Licenses." These activities constituted one quarterly operator simulator training inspection sample.b. Findinqs No findings were identified.

1R12 Maintenance

Effectiveness (71111J2Q - 3 samples)lnspection Scope The inspectors reviewed performance-based problems involving selected in-scope structures, systems, or components (SSCs) to assess the effectiveness of the maintenance program. The reviews focused on the following aspects when applicable:

r Proper maintenance rule scoping in accordance with 10 CFR Part 50.65;. Characterization of reliability issues;. Changing system and component unavailability;. 10 CFR 50.65 (aX1) and (a)(2) classifications;. ldentifying and addressing common cause failures;. Appropriateness of performance criteria for SSCs classified (aX2); and. Adequacy of goals and corrective actions for SSCs classified (aX1).The inspectors reviewed system health reports, maintenance backlogs, and Maintenance Rule basis documents.

The documents reviewed are listed in the Attachment.

The following systems were selected for review.o Control rod drive hydraulic system;. ESW system; and. Standby liquid control (SLC) system.These activities constituted three quarterly maintenance effectiveness inspection samples.Enclosure b. Findinqs No findings were identified.

1R13 Maintenance

Risk Assessments and Emeroent Work Control (71111

.13 - 5 samples)a. Inspection

Scope The inspectors reviewed maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work. The inspectors reviewed whether risk assessments were performed as required by 10 CFR 50.65(a)(4), and were accurate and complete.

When emergent work was performed, the inspectors reviewed whether plant risk was promptly reassessed and managed. The documents reviewed are listed in the Attachment.

The reviews focused on the following activities:

The week of August 15, that included 'A' and 'C' EDG monthly surveillance test, division 1 anticipated transient without scram (ATWS) pressure instrument quarterly surveillance test, 'A' SLC system quarterly function test, 'A' core spray quarterly surveillance test, and emergent maintenance to identify and repair a leak in the west dieselfire pump cooling system.The week of August 29, that included 'B' and 'D' EDG monthly surveillance test, division 2 ATWS pressure instrument quarterly surveillance test, 'B' SLC system quarterly function test, 'B' core spray quarterly surveillance test, and emergent maintenance to replace the 'B' core spray hold pump discharge check valve.The week of September 5, that included a one day maintenance outage for outgoing 345 kV line 1, planned maintenance on the 'B' reactor protection system (RPS)motor-generator, testing of the 'B' RPS electrical protection assemblies, 'B' average power range monitor system flow bias channelfunctional test, torus-to-drywell vacuum breaker operability test, main steam isolation valve limit switch instrument quarterly surveillance test, and emergent maintenance to replace the 'B' core spray hold pump seal.The week of September 19, that included reactor core isolation cooling (RCIC)system instrumentation and pump quarterly surveillance tests, replacement of the 'A'electro-hydraulic control pump, a one day maintenance period for the 'A' RHR service water system, and emergent maintenance to troubleshoot a speed indication problem with the 'A' reactor water recirculation pump, troubleshoot a startup transient speed/pressure issue with the RCIC pump, and replace the local frequency meter for the'A'EDG.

The week of September 26, that included high pressure coolant injection system quarterly surveillance test, 'B'and 'D' EDG monthly surveillance test, a planned power reduction to 65 percent for a control rod sequence exchange, single control rod scram time testing and blade interference monitoring, backwashing main condenser water boxes, and main turbine valve testing, 'B' RHR quarterly surveillance test to perform increased frequency vibration monitoring.

I These activities constituted five maintenance risk assessments and emergent work control inspection samples.b. Findinqs No findings were identified.

1R15 Operabilitv

Evaluations (71111.15 - 5 samples)a. Inspection Scope The inspectors reviewed operability determinations to assess the acceptability of the evaluations; the use and control of applicable compensatory measures; and compliance with technical specifications (TSs). The inspectors' reviews included verification that the operability determinations were conducted as specified by EN-OP-104, "Operability Determination Process." The technical adequacy of the determinations was reviewed and compared to the TSs, UFSAR, and associated design basis documents (DBDs).The inspection focused on the following operability reviews: CR-JAF-201 1-03517 concerning the effect of inaccurate period meter indication on'A' source range monitor operability; CR-JAF-2011-04281concerning RPS relay time response testing and the criteria for testing RPS relay 05A-K101C, reactor pressure instrument; CR-JAF-2011-04411 concerning continued operability of the 'B' core spray system while its hold (keep full) pump was isolated due to reverse leakage through the discharge check valve and the keep full function was being performed by the condensate transfer system ;. CR-JAF-2011-04457 concerning continued operability of four control rods after receiving notification that the vendor's revised channelfriction metric indicated that these control rods may experience degraded performance during insertion; and. CR-JAF-2011-04774 concerning continued operability of the RCIC system with a degraded check valve in the test return line to the CST.These activities constituted five operability evaluation inspection samples.b. Findinqs No findings were identified.

1R18 Plant Modifications

(71111.18 - 2 samples)a. lnspection Scope The inspectors assessed the adequacy of the 10 CFR 50.59 evaluations for the following permanent and temporary modifications respectively.

The inspectors' reviews considered whether the installations were consistent with the modification documentation, that the drawings and procedures were updated as applicable, and that the post-installation testing was adequate.

The following reviews represented one permanent modification inspection sample and one temporary modification inspection sample: Enclosure 10 Permanent modification of the RPS to support RPS test box usage during surveillance testing, thereby preventing initiation of actual half scrams due to testing, performed in accordance with Engineering Change (EC) 15347, "lnstall Pomana Type Test Jacks in Panels 09-15, 09-17 for RPS Test Box Use;" and Temporary modification of the 'A' and 'B' reactor water recirculation motor-generators that recalibrated the tachometer generator voltage regulator circuits to produce a lower voltageto-speed response, performed in accordance with EC 25477 and EC 25480, "Recirc Tach Generator 02-184P-1A/B(TACH)115V Output Acceptance." b.Findinqs No findings were identified.

1 R19 Post-Maintenance Testinq (PMT) (71 1 1 1

.19 - 6 samples)a.Inspection

Scope The inspectors reviewed post-maintenance test procedures and associated testing activities for selected risk-significant mitigating systems to assess whether the effect of maintenance on plant systems was adequately addressed by control room and engineering personnel.

The inspectors verified whether test acceptance criteria were clear, demonstrated operational readiness, and were consistent with DBDs; test instrumentation had current calibrations, adequate range, and accuracy for the application; and tests were performed, as written, with applicable prerequisites satisfied.

Upon completion, the inspectors verified whether equipment was returned to the proper alignment necessary to perform its safety function.

PMT was evaluated for conformance with the requirements of 10 CFR Part 50, Appendix B, Criterion Xl, "Test Control." The documents reviewed are listed in the Attachment.

PMT activities associated with the following WOs were reviewed:. WO 00228000, preventive maintenance on the'A' standby gas treatment (SGT)system;. WO 5203502A, preventive maintenance replacement of 05A-K128D, an RPS relay for annunciator 09-5-2-60; o WO 29026203, replacement of 'A' EDG local frequency meter;. WO 52222339, RPS reactor pressure instrument response time testing of 05A-K101C;. WO 23477801, rebuild core spray'B'hold pump; and. WO 52038354, replacement of RCIC low steam pressure master trip unit, 13MTU-287C.These activities constituted six PMT inspection samples.Findinqs No findings were identified.

b.Enclosure 11 1R22 Surveillance Testinq (71111.22 - 7 samples)a. Insoection Scope The inspectors witnessed performance of surveillance tests (STs) and/or reviewed test data of selected risk-significant SSCs to assess whether the SSCs satisfied TSs, UFSAR, technical requirements manual, and station procedure requirements.

The inspectors reviewed whether test acceptance criteria were clear, demonstrated operational readiness, and were consistent with DBDs; test instrumentation had current calibrations, adequate range, and accuracy for the application; and tests were performed, as written, with applicable prerequisites satisfied.

Upon ST completion, the inspectors verified that equipment was returned to the status specified to perform its safety function.

The following STs were reviewed:. ST-2AL, "RHR Loop A Quarterly Operability Test (lST)," Revision 31;. ST-2XA, "RHR service Water Loop A Quarterly Operability Test (lST)," Revision 13;. ST-2AM, "RHR Loop B Quarterly Operability Test (lST)," Revision 31;. ST-24J, "RCIC Flow Rate and Inservice Test (lST),' Revision 41;. ISP-10OD-RPS, "RPS Instrument Functional TesUCalibration (ATTS)," Revision 37;. ST-3PB, "Core Spray Loop B Quarterly Operability," Revision 21; and o ISP-16, "Drywell Floor Drain Sump Flow Loop FunctionalTesUCalibration*," Revision 36.These activities represented seven surveillance testing inspection samples.b. Findinos No findings were identified.

2. RADIATION

SAFETY Cornerstone:

Occupational Radiation Safety and Public Radiation Safety

2RS1 Radioloqical

Hazard Assessment and Exposure Controls (71124.01-1 sample)a. Inspection Scope The inspectors reviewed the performance indicators for the Radiation Cornerstone, recent operational occurrences and the latest quality assurance audit of the Radiation Protection program.Radioloqical Hazard Assessment The inspectors reviewed changes to plant operations that may result in a significant new radiological hazard for onsite workers or members of the public since the last inspection.

The inspectors verified that FitzPatrick staff have assessed the potential impact of these changes and has implemented periodic monitoring, as appropriate, to detect and q uantify the rad iolo gical hazard.Recent radiological surveys from more than six plant areas were reviewed by the Enclosure 12 inspectors to evaluate the thoroughness and frequency of the surveys and that they were appropriate based on the radiological hazards.The inspectors conducted walkdowns and performed independent radiation surveys of the facility, including radioactive waste processing, storage, and handling areas, to evaluate the existing radiological conditions and the efficacy of the associated radiological postings and controls.The inspectors observed and evaluated the following radiological risk-significant work activity:

Placement of a shield lid on top of a loaded on-site storage container in the radwaste truck bay (a transient locked high radiation area (HRA)).With respect to the above work activity, the inspectors verified that appropriate prework surveys were performed and were sufficient to identify and quantify the radiological hazards and to establish adequate protective measures.

In addition, the inspectors reviewed applicable radiological surveys associated with this work activity to determine if hazards were properly identified, including the following:

identification of hot particles, the presence of alpha emitters, the potentialfor airborne radioactive materials, the hazards associated with work activities that could negatively affect the radiological conditions, and any significant radiation field dose gradients that could result in nonuniform exposures of the body. The inspectors selected at least five air sample survey records during 2011 and verified that the samples were collected and counted in accordance with FitzPatrick procedures.

The inspectors observed work in potential airborne areas to evaluate if applicable air monitoring was representative of the breathing air zone of the workers. The inspectors also reviewed the use of continuous air monitors to monitor real-time airborne conditions in accordance with FitzPatrick procedures.

The inspectors verified that FitzPatrick's program for monitoring loose surface contamination in areas of the plant was adequate to assess the potential for airborne contamination conditions.

Instructions to Workers The inspectors observed various radioactive material containers and verified that they were labeled and controlled in accordance with 10 CFR Parl2Q requirements.

Radiation work permits (RWPs) associated with the radiological risk-significant work activities listed above were evaluated by the inspectors to identify what work control instructions or control barriers were specified and that plant-specific technical specification HRA requirements were met, including the use of applicable electronic personal dosimeter alarm setpoints that were specified in conformance with survey indications and plant policy.The inspectors reviewed one electronic personal dosimeter dose rate alarm occurrence that was documented in a CR. The inspectors verified that FitzPatrick staff responded appropriately to the occurrence and that corrective actions and dose evaluations were adequate.Enclosure 13 Contamination and Radioactive Material Control The inspectors conducted observations at the main radiological controlled area egress location to observe the performance of personnel surveying and releasing material for unrestricted use to verify that those activities were performed in accordance with plant procedures and the procedures were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site.The inspectors reviewed FitzPatrick's criteria for the survey and release of potentially contaminated material and verified that the radiation detection instrumentation was being used at its most effective sensitivity capability.

The inspectors selected three sealed sources from FitzPatrick's inventory records and verified that the required semi-annual leak tests were performed.

The inspectors verified that there have been no changes in the inventory of sources currently listed in the National Source Tracking System.Radioloqical Hazards Control and Work Coveraqe During tours of the facility and review of the work activity listed above, the inspectors evaluated the ambient radiological conditions and verified that existing conditions were consistent with posted surveys, RWPs, and worker briefings, as applicable.

During these work activity performance observations, the inspectors verified the adequacy of radiological controls, such as required surveys (including system breach radiation, contamination, and airborne surveys), radiation protection job coverage (including audio and visual surveillance for remote job coverage), contamination controls, and means of using electronic personal dosimeters in high noise areas as HRA monitoring devices.The inspectors verified that radiation monitoring devices were placed on the individual's body appropriately to monitor dose from external radiation sources. This review included high-radiation work areas with significant dose rate gradients.

The inspectors reviewed two RWPs for work within potential airborne radioactivity areas with the potential for individual worker internal exposures.

The inspectors evaluated the airborne radioactivity controls and monitoring, including potentials for significant airborne radioactivity levels (e.g., grinding, grit blasting, system breaches, entry into tanks, cubicles, reactor cavities).

For these selected potential airborne radioactive areas, the inspectors verified the appropriate use of high-efficiency particulate air ventilation system operation.

The inspectors examined the station's physical and programmatic controls for highly activated or contaminated materials (nonfuel)stored within the spent fuel pool and verified that appropriate controls were in place to preclude inadvertent removal of these materials from the pool.Tours within the radiological controlled area were conducted by the inspectors to evaluate radiological postings and physical controls for HRAs and very high radiation areas (VHRAs) with respect to regulatory requirements.

14 Risk-Siqnificant Hiqh Radiation Area and Verv Hiqh Radiation Area Controls The inspectors discussed with the radiation protection manager and one first-line health physics supervisor, the controls and procedures for high-risk HRAs and VHRAs and actions to be taken during changing plant conditions.

b.Radiation Worker Performance During observation of the work activity listed above, the inspectors observed radiation worker performance with respect to applicable radiation protection work requirements to determine if workers were aware of the significant radiological conditions in their workplace and their work performance was within the RWP control/limit requirements specified for the work performed.

The inspectors reviewed several radiological problem reports since the last inspection that identified the cause of the event to be human performance errors to determine if there was an observable pattern traceable to a similar cause and if this perspective matched the corrective action approach taken by station personnelto resolve the reported problems.Radiation Protection Technician Proficiencv During observation of the work activity listed above, the inspectors evaluated the performance of radiation protection technicians with respect to radiation protection work requirements and determined that technicians were aware of the radiological conditions in their workplace and that the RWP controls/limits and their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities.

The inspectors reviewed several radiological problem reports since the last inspection that identified the cause of the event to be radiation protection technician error to determine if there was an observable pattern traceable to a similar cause and if this perspective matched the corrective action approach taken by FitzPatrick staff to resolve the reported problems.Problem ldentification and Resolution The inspectors verified that problems associated with radiation monitoring and exposure control were being identified by FitzPatrick personnel at an appropriate threshold and were properly addressed for resolution in the corrective action program (CAP).Findinqs No findings were identified.

Occupational Dose Assessment (7 1 124.04)2RS4

a. Inspection Scope

The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report on FitzPatrick.

15 The inspectors verified that FitzPatdck's personnel dosimeters that require processing were NVLAP accredited.

The inspectors verified the vendor's NVLAP accreditation.

The inspector ensured that the approved irradiation test categories for each type of personnel dosimeter used were consistent with the types and energies of the radiation present, and how the dosimeter was being used.The inspectors verified that FitzPatrick informed workers, as appropriate, of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily)declaring a pregnancy.

The inspectors selected individuals who had declared their pregnancy during the current assessment period, and verified that FitzPatrick's radiological monitoring program for declared pregnant workers was technically adequate to assess the dose to the embryo/fetus.

The inspectors reviewed the exposure results and monitoring controls employed by FitzPatrick and with respect to the requirements of 10 CFR Part 20. Two workers had declared pregnancies in the past 12 months.b. Findinos No findings were identified.

2RS5 Radiation

Monitorinq lnstrumentation (71124.05)

Inspection Scope During the period July 18 through 22,2011, the inspectors conducted the following activities to verify that FitzPatrick personnel were providing accurate and operable radiation monitoring instruments used to 1) monitor areas, materials, and workers to ensure a radiologically safe work environment, and 2) detect and quantify radioactive process streams and effluent releases.

lmplementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, relevant TSs, and FitzPatrick's procedures.

r The inspectors reviewed the UFSAR to identify applicable radiation monitors associated with transient high and VHRAs including those used in remote emergency assessment.

r The inspectors obtained a list of in-service survey instrumentation including air samplers, neutron survey instruments, personnel and small article monitors.

The inspectors reviewed the list to determine if an adequate number of instruments were available to support operations.

o The inspectors reviewed two FitzPatrick self-assessments for contamination and radioactive material control and radiation protection instrumentation and protective equipment.

r The inspectors reviewed source check and calibration procedures for the radiation monitoring instruments.. The inspectors reviewed alarm set-points for area radiation monitors and the basis for the set-points.

o The inspectors reviewed the alarm sefpoints and basis for effluent monitors and the methods used to calculate the set-points.

16 Walkdowns and Observations o The inspectors walked down the following radiation monitors: a) 17-04-1 drywell monitor'A';

b) 17-04-2 drywell monitor'B';

c) 17-RM-150'A'/'B' steam jet air ejector(SJAE)off-gas;d) 17RM-461 TB exhaust;e) 17RM-351 service water;f) 17RM-350 liquid radwaste effluent monitor; and g) 17RM-456 refuelfloor exhaust;. The inspectors verified that configuration of the monitors aligned with the Offsite Dose Calculation Manual (ODCM) descriptions.

The inspectors looked for monitor degradation and out of service tags.o The inspectors verified the calibration and source checkof 10 portable survey instruments and observed their material condition.

o The inspectors observed source checks of portable survey instruments.. The inspectors walked down eight area radiation monitors and verified the readout with a portable survey instrument.

r The inspectors verified periodic source checks were performed for two personnel monitors and two small article monitors.Calibration and Testinq Prooram. The inspectors verified for three effluent monitor instruments that channel calibration and functional tests were performed consistent with TSs and the ODCM. The inspectors also verified that the monitors were calibrated with National Institute of Standards and Technology (NIST) traceable sources that represent the plant nuclide mix.o The inspectors verified that the effluent monitor alarm set-points were established at or below the ODCM limits.Laboratorv I nstrumentation. The inspectors verified laboratory analytical instruments daily performance checks and calibration data indicated the frequency of calibrations was adequate and there was no indication of degraded instrument performance.

The inspectors reviewed performance for the planchet counter-S's and the high purity germanium and germanium lithium detector Nos. 1 ,2,3, and 4 systems.Whole Bodv Counter. The inspectors reviewed the methods and sources used to perform whole body counter functional checks before daily use and verified the check sources are appropriate and align with the plant isotopic mix.. The inspectors reviewed the most recent calibration report for the whole body counter and verified the sources used were representative of the plant source term and that appropriate calibration reference devices were used.Enclosure 17 Post Accident Monitorinq lnstrumentation. The inspectors reviewed a post accident high-range monitor calibration.

e The inspectors verified that an electronic calibration was performed for all range decades above 10 rem/hour and that at least one decade at or below 10 rem/hour were calibrated using an appropriate radiation source.o The inspectors verified that the acceptance criteria were reasonable.. The inspectors reviewed the calibration of two high-range effluent monitors and reviewed their availability.

o The inspectors reviewed FitzPatrick's capability to collect high-range, post accident iodine effluent samples.. There was no opportunity to observe electronic or radiation calibration of these instruments during this inspection:

portal monitors, personnel contamination monitors.

and small article monitors.. The inspectors verified that the alarm set-point values for one of each type of these instruments were reasonable to ensure that licensed material was not released from the site.o The inspectors reviewed the calibration documentation for each instrument selected.Portable Survev lnstruments.

Area Radiation Monitorinq Svstem. Electronic Dosimetrv, and Air Samplers/

Continuous Atmospheric Monitorinq (CAMs). The inspectors reviewed calibration documentation for at least one of each type of instrument.

The inspectors reviewed detector measurement geometry and calibration methods and had the technician demonstrate the use of its instrument calibrator.. The inspectors verified that FitzPatrick staff took appropriate corrective action for instruments found significantly out of calibration and evaluated the possible consequences of instrument use since the last successful calibration or source check.lnstrument Calibrator. The inspectors reviewed the current output values and verified FitzPatrick periodically measured calibrator output over the range of instruments used.o The inspectors verified the measurement device was calibrated by a facility using N IST traceable sources.Calibration and Check Sources. The inspectors verified the check sources used were representative of the types and energies of the radiation encountered in the plant.Problem ldentification and Resolution. The inspectors verified that problems associated with radiation monitoring instrumentation were being identified at the appropriate threshold and entered into the CAP.Enclosure 18 b. Findinos No findings were identified.

2RS7 Radiolooical

Environmental Monitorinq Proqram (71124.07 - 1 sample)a. Inspection Scope The inspectors reviewed the annual radiological environmental operating reports and the results of any FitzPatrick assessments since the last inspection, to verify that the radiological environmental monitoring program (REMP) was implemented in accordance with the plant TSs and the ODCM. The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, interlaboratory comparison program, and analysis of data.The inspectors reviewed the ODCM to identify locations of environmental monitoring stations.The inspectors reviewed the UFSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61 ,"Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine if FitzPatrick was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.

The inspectors walked down air sampling stations and thermoluminescent dosimeter (TLD) monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition' For the air samplers and TLDs selected above, the inspectors reviewed the calibration and maintenance records to verify that they demonstrate adequate operability of these components.

Additionally, the inspectors reviewed the calibration and maintenance records of composite water samplers as available.

The inspectors verified that FitzPatrick staff had initiated sampling of other appropriate media upon loss of a required sampling station.The inspectors observed the collection and preparation of environmental samples from different environmental media (e.9., ground and surface water, milk, vegetation, sediment, and soil) as available.

The inspectors verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear Power Plants," and FitzPatrick procedures.

The inspectors verified that the meteorological data readout and recording instruments in the control room and at the tower were operable.Enclosure 19 The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors reviewed FitzPatrick's assessment of any positive sample results. The inspectors reviewed the associated radioactive effluent release data that was the source of the released material.The inspectors selected SSCs that involved or could reasonably involve licensed material for which there is a credible mechanism for licensed material to reach ground water, and verified that FitzPatrick had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to ground water. There have been no significant changes in this program area since the last inspection.

The inspectors verified that records, as required by 10 CFR Part 50.75(9), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.The inspectors reviewed any significant changes made by FitzPatrick to the ODCM as the result of changes to the land census, long-term meteorological conditions (three year average), or modifications to the sampler stations since the last inspection.

The inspectors reviewed technicaljustifications for any changed sampling locations.

The inspectors verified that FitzPatrick performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors verified that the appropriate detection sensitivities with respect to TS/ODCM were used for counting samples. The inspectors reviewed quality control charts for maintaining radiation measurement instrument status and actions taken for degrading detector performance.

The inspectors reviewed the results of FitzPatrick's interlaboratory comparison program to verify the adequacy of environmental sample analyses performed by FitzPatrick.

The inspectors verified that the interlaboratory comparison test included the media/nuclide mix appropriate for the facility.The inspectors verified that problems associated with the REMP were being identified by FitzPatrick at an appropriate threshold and were properly addressed for resolution in FitzPatrick's CAP. The inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by FitzPatrick that involved the REMP.b. Findinqs No findings were identified.

OTHER ACTIVITIES

4QA1 Performance Indicator Verification (71151 - 6 samples).1 Mitiqatinq Svstems Cornerstone - Safetv Svstem Functional Failures (1 sample)Enclosure a.20 lnspection Scope The inspectors sampled FitzPatrick's submittals for the safety system functional failures performance indicator for the period of October 1,2Q1Q, through June 30, 201 1. To determine the accuracy of the performance indicator data reported during that period, the inspectors used definitions and guidance contained in Nuclear Energy lnstitute (NEl)99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed licensee event reports (LERs) and NRC integrated inspection reports to validate the accuracy of the submittals.

Findinqs No findings were identified.

Barrier Inteoritv Cornerstone - Reactor Coolant Svstem (RCS) Specific Activitv and RCS Leakaqe (2 samples)Inspection Scope The inspectors reviewed FitzPatrick staff's submittals for the RCS specific activity and RCS leakage performance indicators for the period of October 1, 2010, through June 30, 2Q11. To determine the accuracy of the performance indicator data reported during that period, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed RCS sample analysis and control room log summaries and to validate the accuracy of the submittals.

Findinos No findings were identified.

lnitiatinq Events Cornerstone - Unolanned Scrams, Unplanned Power Chanoes. and Unplanned Scrams with Complications (3 samples)lnspection Scope The inspectors reviewed FitzPatrick staff's submittals for the unplanned scrams per 7,000 critical hours, unplanned power changes per 7,000 critical hours, and unplanned scrams with complications performance indicators for the period of October 1,2010, through June 30, 2011. To determine the accuracy of the performance indicator data repo(ed during that period, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors reviewed control room logs and NRC integrated inspection reports to validate the accuracy of the submittals.

b..2 a.b..3 Enclosure b.21 Findinos lntroduction:

The inspectors identified an unresolved item (URl) associated with FitzPatrick staff's interpretation of guidance for reporting unplanned power changes per 7,000 critical hours. Specifically, Entergy personnel did not report three power reductions during the second quarter of 2011 that the inspectors considered to have been reportable.

The unplanned power changes per 7,000 critical hours performance indicator is defined as the number of unplanned changes in reactor power of greater than 20 percent of full-power, per 7,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of critical operation excluding manual and automatic scrams.Description:

On January 11,2011, FitzPatrick operators performed a power reduction to 55 percent to plug a leaking condenser tube. This power reduction was reported in the first quarter performance indicators as an unplanned power change. The root cause evaluation of this event determined that additional condenser tube leaks could occur. As a result, an operational decision-making issue (ODMI) action plan was developed by Entergy staff, which established four action levels for chemistry parameters (condensate demineralizer influent (CDl) conductivity, reactor water conductivity, and reactor water chloride concentration).

These action levels provide guidance for operators to perform a range of actions, such as a power reduction to support condenser tube plugging.

The action plan was established on April 4, 2011.On May 6,2011, operators observed indications of a rapid increase in hotwell conductivity and determined that CDI conductivity increased to above action level 3. In accordance with the ODMI action plan operators reduced power to 55 percent later that day to identify and plug the leaking main condenser tube.The inspectors reviewed the guidance for reporting performance indicators in NEI 99-02,"Regulatory Assessment Performance lndicator Guideline," Revision 6. Concerning unplanned power reductions per 7,000 critical hours, the guidance states, "This indicator captures changes in reactor power that are initiated following the discovery of an off-normal condition.

lf a condition is identified that is slowly degrading and the licensee prepares plans to reduce power when the condition reaches a predefined limit, and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> have elapsed since the condition was first identified, the power change does not count. lf, however, the condition suddenly degrades beyond the predefined limits and requires rapid response, this situation would count." In follow-up questions regarding the May 6 down power Entergy staff indicated that the down power was planned as a contingency action in the ODMI action plan and that, because the initial condition for which the action plan was written occurred greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the down power, the down power should not be counted. The inspectors considered that notwithstanding an action plan, the condition was best described as a suddenly degrading condition that resulted in operators decreasing power the same day to address the condition.

Therefore, it appeared to be appropriate to report the May 6 down power as unplanned.

In addition, the inspectors determined that FitzPatrick operators performed two power reductions to 75 percent on June 7, and June 9, 2011, to support cleaning main condenser water boxes. This cleaning was necessary to address fouling that occurred during planned maintenance on the lake intake travelling screens. The fouling was the result of operation of circulating water system gates which caused sediment to be Enclosure 4cA2 22 ingested by the circulating water system. The inspectors determined that FitzPatrick staff did not report these two down powers as unplanned in the second quarter Pl.The inspectors reviewed the applicable guidance in NEI 99-02 which indicated that"Anticipated power changes greater than 20 percent in response to expected environmental problems (such as accumulation of marine debris, biological contaminants, animal intrusion, environmental regulations, or frazil icing) may qualify for an exclusion from the indicator.

The licensee is expected to take reasonable steps to prevent intrusion of animals, marine debris, or other biological groMh from causing power reductions.

Intrusion events that can be anticipated as a part of a maintenance activity or as part of a predictable cyclic behavior would normally be counted, unless the down power was planned 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in advance . . ." FitzPatrick's staff indicated they considered this allowance to be applicable, in that they had taken reasonable steps to prevent intrusion by cleaning the lake water forebays prior to the maintenance.

Because this activity had not been performed on line since the traveling screens had been replaced, station personnel also considered that they could not reasonably have anticipated the severity of the fouling that occurred.

Finatty, FitzPatrick staff included a contingency down power in the work week schedule, and noted in the applicable operating procedure that operation of the gates may require a power reduction to perform condenser cleaning.Notwithstanding an acknowledgement by FitzPatrick staff in their procedures and work week schedule as to the possibility of a need for a plant down power, the inspectors considered that these two down power conditions were anticipated as part of a maintenance activity and appeared to have not been plannedT2 hours in advance.Therefore the inspectors had questions as to the appropriateness of not reporting the plant down powers on June 7 , and June 9, 2011.FitzPatrick staff initiated a review of these issues as part of the NRC and industry performance indicator "frequently asked questions" (FAO) process. This item remains unresolved pending further information from the FAQ process. (URl 05000333/201 1004-01, Unplanned Power Reduction Pl Reporting)ldentification and Resolution of Problems (71152 - 2 samples)Review of ltems Entered into the Corrective Action Proqram Inspection Scope As required by lnspection Procedure71152, "ldentification and Resolution of Problems," to identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into FitzPatrick's CAP. The review was accomplished by accessing FitzPatrick's computerized database for CRs and attending CR screening meetings.

In accordance with the baseline inspection procedures, the inspectors selected items across the Initiating Events, Mitigating Systems, Barrier Integrity, and Public Radiation Safety cornerstones for additionalfollow-up and review. The inspectors assessed FitzPatrick personnel's threshold for problem identification, the adequacy of the Gause analyses, and extent of condition review, operability determinations, and the timeliness of the specified corrective actions..1 a.Enclosure 23 b..2 a.The inspector reviewed 12 corrective action CRs that were initiated since the last radioactive effluent inspection that were associated with this program area. The inspector verified that problems identified by these CRs were properly characterized in FitzPatrick's event reporting system and that applicable causes and corrective actions were identified commensurate with the safety significance of the radiological occurrences.

Findinqs and Observations No findings were identified.

Annual Sample: Review of a Low Pressure Coolant Iniection Valve Demand Failure (1 sample)Inspection Scope The inspectors selected CR-JAF-2010-04912 as a problem identification and resolution sample for a detailed follow-up review. This CR documented that on August 30, 2010, the 'B' RHR system low pressure safety injection (LPSI) outboard motor operated valve (MOV), 10MOV-278, failed to open during a routine surveillance test. 10MOV-27B is a normally open valve that was closed to maintain reactor coolant pressure boundary while stroke testing the LPSI inboard isolation valve, 10MOV-258.

Entergy staff initiated corrective actions to replace the lower motor operator contact assembly (fingerbase), send the fingerbase for chemical analysis of residue on the contacts, and inspect upper and lower fingerbases for all risk significant MOVs in close proximity to 10MOV-278.

The inspectors assessed FitzPatrick's problem identification threshold, apparent cause evaluation (ACE), extent of condition reviews, operability evaluations, and the prioritization and timeliness of corrective actions to determine whether FitzPatrick was appropriately identifying, characterizing, and correcting problems associated with the identified issues and whether the planned or completed corrective actions were appropriate to prevent recurrence.

Findinqs and Observations No findings were identified.

The inspectors determined that FitzPatrick staff properly implemented their CAP regarding the initial discovery of the reviewed issue. The CR packages were complete and included an ACE, operability evaluations, extent of condition reviews, use of operating experience, and contained implemented and planned corrective actions. Additionally, the elements of the CRs, ACE, and operability evaluations were detailed and thorough.

lmplemented and planned corrective actions were appropriate to minimize the potential of recurrence.

Additionally, the inspectors reviewed chemical analysis performed by an independent contracted laboratory on the surface contamination of the contact assembly fingers.Analysis showed that the contact fingers had an even black tarnish consisting of sulfur.The analysis determined that sulfur can be damaging to electrical contacts due to causing increased contact resistance.

However, the analysis also showed that if voltage and current across the contacts was sufficient the damaging effects of the sulfide would be negligible.

FitzPatrick staff concluded that source of the tarnish layer was unknown.b.Enclosure 24 Per the recommendation in the independent analysis, FitzPatrick staff reviewed the material condition of the upper and lower fingerbases for risk significant MOVs in close proximity to 10MOV-278.

The inspectors concluded that a more thorough extent of condition may have included a review of 10MOV-278 mainlenance records to determine if other risk significant MOVs had been subjected to similar conditions and maintenance which may have led to contact tarnishing.

Further, any MOVs identified as being susceptible to contact tarnishing could then have been included in the review of upper and lower fingerbases.

However, the inspectors concluded that FitzPatrick's extent of condition was adequate because the tarnish layer on the contacts was not considered to be the cause of the MOV failure and there have been no similar MOV failures..3 Annual Sample: Review of the Operator Workaround Proqram (1 sample)a. Inspection Scope FitzPatrick operations department personnel monitor the impact of plant deficiencies on operational response capabilities in accordance with EN-FAP-OP-006, "Operator Aggregate lmpact Index Performance Indicator," Revision 0. As inputs, this procedure utilizes the plant effect code that was assigned to the equipment deficiency in the associated work order, and the age of active equipment tagouts. From this, plant deficiencies such as operator workarounds, operator burdens, control room deficiencies and alarms, and longstanding tagouts, are tallied and converted to a performance indicator on a monthly basis. lf the performance indicator is above a threshold value, then a more in-depth assessment of the aggregate impact of plant deficiencies is performed in accordance with surveillance test procedure ST-99H, "Operations Cumulative lmpact Assessment," Revision 10. FitzPatrick personnel also perform this assessment on a periodic basis.The inspectors reviewed the results of ST-99H, completed on April 5,2011, including the resolution of items identified in the assessment.

The inspectors reviewed operator workarounds (deficient conditions that require compensatory operator actions for operation during off-normal plant conditions), operator burdens (deficient conditions that require compensatory operator actions for operation during normal plant conditions), control room deficiencies such as non-functional or incorrect display information and equipment controls requiring some off-normal mode of operation, and longstanding tagouts, to assess their effect on the operator's ability to implement operating procedures under normal, off-normal, and emergency conditions.

b. Findinqs and Observations No findings were identified.

The inspectors determined that the station's CAP was effectively used to identify and resolve operator workaround conditions.

4OA3 Follow-up

of Events and Notices of Enforcement Discretion (71153 - 1 sample).1 (Closed) LER 05000333/2011002-00, Failure to lsolate the Reactor Building Results in a Condition Prohibited by Technical Specifications On January 10,2011, the 'A' refueling floor exhaust radiation monitor was declared inoperable for maintenance.

For this condition, TS 3.3.6.2 requires that the reactor building ventilation system be isolated and that the standby gas treatment (SGT) system Enclosure 25 be placed in operation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. At the start of this maintenance activity this configuration had already been established to support another unrelated maintenance activity.

Operators did not adequately track the TS requirements for the 'A' refuel floor exhaust radiation monitor being inoperable, and as a result, reactor building ventilation was restored at 12:30 pm after completion of the other maintenance activity.

The following day, operators recognized the error and isolated the reactor building ventilation system at2:54 pm.The inspectors reviewed the LER and CR-JAF-2011-00189 regarding this event. The enforcement aspects of the TS violation are discussed in Section

4OA7 of this report.This LER is closed.4OA4 Supplemental

Inspections

.1 Licensee Strike Continqencv

Plans (92709)a. Inspection Scope The contract between Entergy and the FitzPatrick collective bargaining unit was due to expire during this inspection period. The inspectors evaluated the adequacy of Entergy's strike contingency plan to determine if the required minimum number of qualified personnel were available for the proper operation and safety of the facility, and to determine if the plan complied with TS and CFR requirements.

Prior to expiration, a new contract agreement was reached and subsequently ratified.b. Findinqs No findings were identified.

4OA5 Other Activities

.1 Operation

of an Independent Spent Fuel Storaqe Installation (lSFSl) at Operatinq Plants (60855.1)a. Inspection Scope The inspectors verified by direct observation and independent evaluation that FitzPatrick performed loading activities at the ISFSI in a safe manner and in compliance with applicable procedures.

b. Findinqs No findings were identified.

4OAO Meetinos.

lncludinq Exit Exit Meetinq Summarv The inspectors presented the inspection results to Mr. B. Sullivan and other members of Entergy's management at the conclusion of the inspection on October 19, 2011. The Enclosure 26 inspectors asked Entergy personnel whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identified by Entergy's personnel.

4C.A7 Licensee-ldentified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation.. TS limiting condition for operation (LCO) 3.3.6.2 Condition A requires that, with one channel of the refueling floor exhaust radiation monitors inoperable, the channel be placed in trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. lf Condition A is not met, Condition C actions C.1.1 and C.1

.2 require that the reactor building ventilation

system be isolated and the standby gas treatment system be placed in operation within one hour. FitzPatrick staff identified that, contrary to the above, on January 11,2011, the TS LCO Condition A required action was not completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of having made the'A' refueling floor exhaust radiation monitor inoperable, and that the Condition C required actions C.1.1 and C.1.2 were not subsequently completed within one hour.The inspectors determined this TS violation was of very low safety significance (Green) because it represented only a degradation of the radiological barrier function provided for the secondary containment, as discussed in Inspection Manual Chapter 0609.04, "lnitial Screening and Characterization of Findings." This issue was entered into FitzPatrick's CAP as CR-JAF-2O11-00189.

ATTACHMENT:

=SUPPLEMENTAL

INFORMATION=

KEY POINTS OF CONTACT

Enterqv Personnel

K. Bronson, Site Vice President

B. Sullivan, General Manager, Plant Operations

C. Adner, Manager, Operations

V. Bacanskas, Manager, Design Engineering

C. Brown, Manager, Quality Assurance, Entergy

B. Finn, Director, Nuclear Safety Assurance

D. Koelbel, Sr. Engineer, Fire Protection

G. Sullivan, Acting Manager, Security

J. Pechacek, Manager, Licensing

D. Poulin, Manager, System Engineering

T. Raymond, Manager, Project Management

M. Reno, Manager, Maintenance

P. Scanlan, Manager, Programs and Components

Engineering

E. Wolf, Manager, Radiation

Protection

M. Woodby, Director, Engineering

LIST OF ITEMS

OPEN, CLOSED, AND DISCUSSED

Opened

05000333/2011004-01

Closed

05000333/201

002-00 Unplanned

Power Reduction

Pl Reporting Failure to lsolate the Reactor Building Results in a Condition

Prohibited

by Technica I Specifications

URI LER

Discussed

None Attachment

LIST OF DOCUMENTS

REVIEWED Section 1R01: Adverse Weather Protection Procedures:

AOP-13, "High Winds, Hurricanes and Tornadoes," Revision 13

Section 1R04: Equipment

Aliqnment

OP-13, "Residual Heat Removal System," Revision 95

OP-33, "Fire Protection", Revision 54;OP-14, "Core Spray System," Revision 33 Section 1R05: Fire Protection Procedures:

PFP-PWR29, "switchgear Room-EasUElev.

2' Fire ArealZone lllSW-2," Revision 2

PFP-PWR3O, "switchgear Room-WesVElev.

2' Fire ArealZone

IC/SW-1," Revision 2

PFP-PWR31, "Emergency Diesel Generator Spaces-South/Elev.

2'Fire ArealZone

V/EG-1,

EG-2. EG-s," Revision 2

OP-60, "Diesel Generator Room Ventilation," Revision 8;PFP-PWR14, "Crescent Area-easU

Elevation

27' , 242' Fire ArealZone

XVll/RB-1E," Revision 3

PFP-PWR33, "Pump Rooms (Screenwell)/Elev.

255' Fire Area/Zone Xll/SP-1, Xlll/SP-2, lB/FP-1,

FP-3,'Revision Documents:

JAF-RPT-O4-00478, "JAF Fire Hazards Analysis," Revision 2

DBD-076 TAB lX, "Design Basis Document for Fire Protection, System Safe Shutdown," Revision 5

JAF-ANAL-FPS-01139, "Fire Barrier Analysis, Various Unsealed Penetrations from Crescents and Main Steam Tunnel to Torus," Revision 2

Section 1R06: Flood Protection

Measures Procedures:

EN-DC-346, "Cable Reliability Program," Revision 2 Condition Reports: CR-JAF-2o11-04407

CR-JAF-201144892

CR-JAF-2011-04897

Work Orders: 52285065-01

Section 1R11: Licensed Operator Requalification

Proqram Procedures:

AOP-41, "Feedwater Malfunction," Revision 9

EOP-2, "RPV Control," Revision 9

EOP-3, "Failure to Scram," Revision 9

EOP-3A, "Failure to Scram - ED," Revision 2

EOP-4, "Primary Containment Control," Revision I

Section 1R12: Maintenance

Effectiveness Procedures:

EN-DC-203, "Maintenance Rule Program", Revision 1

EN-DC-204, "Maintenance Rule Scope and Basis," Revision 2

EN-DC-205, "Maintenance Rule Monitoring", Revision 3

EN-DC-206, "Maintenance Rule (aX1) Process," Revision 1

OP-25, "Control Rod Drive Hydraulic System", Revision 80

ST-8Q, "Testing of the Emergency Service Water System", Revision 41 Documents:

JAF-RPT-CRD-02493, "Maintenance Rule Basis Document System 003 Control Rod Drive Hydraulic System", Revision 8 System Health Report, Control Rod Drive Hydraulic System, 2na Quarter,2Ol1

JAF-RPT-MULTI-02294, "Maintenance Rule Basis Document for Service Water Systems Including Sysetm 10 (RHR SW), 46 (Normal SW), and 46-ESW (Emergency

SW)," Revision 10 System Health Report, Emergency Service Water System, 2no Quarter, 2Q11 Quarterly

SLC system health reports for second quarter 2010 through second quarter 2011

JAF-RPT-SLC-O2282, "Maintenance Rule Basis Document System 11, Standby Liquid Control," Revision 6

JENG-APL-11-OO2, "Maintenance Rule (aX1) Action Plan, System 1 1 Standby Liquid Control," Revision 1 Condition Reports: cR-JAF-2007-00625

cR-JAF-2009-03994

CR-JAF-2O10-00894

CR-JAF-2O10-02557

CR-JAF-201

1-00894

Section 1R13: Maintenance

Risk Assessments and Emerqent Work Control Procedures:

AP-05.13, "Maintenance During LCOs," Revision 10

AP-10.10, "On-Line Risk Assessment," Revision 7

EN-WM-104,"On Line Risk Assessment," Revision 4 Attachment Section 1 R15: Operabilitv Evaluations Procedures:

EN-LI-102, "Corrective Action Process," Revision 16

EN-OP-1 04, "Operabitity Determination Process," Revision 5

ISP-104A, "RPS Reactor Pressure Instrument Response Time Test (ATTS)", Revision 0

Section 1R18: Plant Modifications

EN-DC-1 36, "Temporary Modifications," Revision 6

EN-DC-115, "Engineering Change Process," Revision 10

EN-DC-1 17, "Post Modification Testing and Special Instructions," Revision 4 Documents:

EC 15347 , "lnstall Pomana Type Test Jacks in Panels 09-15, 09-17 for RPS Test Box Use"

EC 25477, "Recirc Tach Generator

2-184P-1A (TACH) 1 15V Output Acceptance"

EC 25480, "Recirc Tach Generator

2-184P-1B (TACH) 115V Output Acceptance"

Section 1R19: Post Maintenance

Testino Procedures:

ST-1MA, "A MCLCS Valve Exercise (lST)", Revision 1

ISP-104A, "RPS Reactor Pressure lnstrument Response Time Testing (ATTS)," Revision 0

ARP 09-5-2-60, "ATTS RPS Div 81 or 82 Gross Fail or TU Inop," Revision 3

ISP-17581, "Reactor and Containment Cooling Instrument Functional Test/Calibration (ATTS)," Revision 16

OP-14, "Core Spray System," Revision 33

IPS-150A, "RCIC Auto lsolation lnstrument Function TesV Calibration (ATTS)," Revision 34

Section 2RS1: Radioloqical

Hazard Assessment and Exposure Controls Procedures:

EN-RP-121, "Radioactive Material Control," Revision.

6,

EN-RP-101, "Access Control for Radiologically Controlled Areas," Revision 6

EN-RP-131, "Air Sampling," Revision.

Documents:

Quality Assurance Audit Report No.

QA-14-2009-JAF-1, "Radiation Protection" Quality Assurance Audit Report No.

QA-14/15-2009-JAF-1, "Radiation Protection

/ Radwaste" Condition Reports: CR-JAF-2o11-01925

CR-JAF-2o11-02747

CR-JAF-2o1

1-03645

CR-JAF-201

1-08585 CR-JAF-2O11-02007

CR-JAF-2O1

1-03076

CR-JAF-2o1

1-03905 CR-JAF-2O11-02394

CR-JAF-2o11-03154

CR-JAF-2011-04367

CR-JAF-2o11-02608

CR-JAF-2O1

1-03350 cR-JAF-2O11-04455

Section 2RS4: Occupational

Dose Assessment Documents:

NVLAP On-Site Assessment Report for Landauer, lnc., May 2010 Personnel Dosimetry Performance Testing Conducted for NVLAP at Pacific Northwest National Laboratory for Landauer, Inc., May 2010

Section 2RSS: Radiation

Monitorinq Instrumentation Procedures:

RP-INST-02.04,"Count Rate Meter, Ludlum Model 177," Revision 6

RP-INST-02.06, "Dose Rate Meter, Bicron Micro-Rem," Revision 3 RP-iNST-02.08, "lon Chamber Dose Rate Meter," Revision 4

RP-INST-03.01, "Area Radiation Monitors," Revision 3

RP-INST-03.03, "Containment Radiation Monitor System Response Test and Preplanned Alternate Monitoring Method," Revision 9

RP-INST-03.04, "PASS Radiation Monitor," Revision 2

RP-I

NST-0 4.01, " Area Radiation Mon itor, Dosimeter Corporation," Revision 5

RP-INST-04.02,"Whole Body Contamination Monitor lPM," Revision 6

EN-RP-308, "SmallArticles Monitor (SAM) Model 9," Revision 4

RP-INST-04.08, "MGPI Telepole WR Extendable

GM Survey Meter," Revision 4

EN-RP-306 , "PM-7 Portal Monitor," Revision 2

RP-INST-05.02, "Electrometer, Victoreen Model 500," Revision 1

SP-03.01, "Main Steam Line and SJAE Radiation Monitor Calibration," Revision 13

SP-03.08, "HR High Range Effluent Monitors," Revision 0

SP-03.08RW, "Radwaste Bldg Gaseous Effluent Monitors Monitor," Revision 1

SP-03.07, "Liquid Process Radiation Monitors," Revision 6

IMP-17 .2, "Process Radiation Monitoring System Liquid Process Radiation Monitors TesVCalibration," Revision 1 5

IMP-17 .12, "VenIilation Radiation Monitor Removal/Return to service for Preventive Maintenance Activities," Revision 14

ISP-17-4A, "Dry Well Continuous Atmospheric Monitoring System," Revision 1

ISP-17-48, "Dry Well Continuous Atmospheric Monitoring System," Revision 1

ISP-26A, "Radwaste Bldg. Exhaust Radiation Monitor ChannelA Functional TesUCalibration," Revision'l Instrument Calibrations Reviewed: Model

RO-20 lon Chamber Survey Meter: #1A0 -

313111; #1107 -

4111111; #1116 - 10/5110;#1118 - 1015110: #1110 -

12113110 Bicron Micro-Rem:#546 - 1Ol28l1Q;#543 -

417110;#544 - 4l7l1O Ludlum Model 177: #348 -

6128111; #366 - 6/29111 Post Accident Sampling System Radiation Monitor: #Rl-507 & #Rl-665 -

416111 Area Radiation Monitor: #19 -

3114111; #24 -

1212110; #26 -

11122110;

1. 30 -

913110 MGPI Telepole WR Extendable

GM Survey Meter: #11694 -

3129111; #16 -

2118111

PM-7 Portal Monitor: #733 -

12111109 Main Steam Line and SJAE Radiation Monitors:

17RM-150A - 8120108: 17RM-1508 -

8130110 High Range Effluent Monitors:

17RM-53A -

12115109;17RM-53B -

918109 Radwaste Building Gaseous Effluent Monitors:

17RM-458A - 8l25l1O;17RM-4588 - 3/16/10 Liquid Process Radiation Monitors:

17RM-351 -

8125110; 17RM-350 -

9111110 Attachment Process Radiation Monitoring System Liquid Process Radiation Monitors:

17RM-350 -611110;17RM-351 -

611110; 17RM-352 -

611110 Ventilation Radiation Monitor: 17RM-4528 -

1119111 DryWell Continuous Atmospheric Monitoring System: 17RM-102A-617111;

17RM-103A -

617111;17RM-102B -

619111; 17RM-1038 -

619111 Radwaste Building, Exhaust Radiation Monitor ChannelA FunctionalTest/Calibration:

17RM-458A -

514111 Post Accident Containment High Range Radiation Monitors:

27RM-104A -

12111109;27RM-1048 -

911110 Condition Reports: CR-JAF-2010-00508

CR-JAF-2010-01

156 cR-JAF-2010-01893

CR-JAF-2010-02130

CR-JAF-2010-02301

CR-JAF-2O10-02500

cR-JAF-2o10-02702

CR-JAF-2010-02764

CR-JAF-2010-02988

CR-JAF-2o10-03090

CR-JAF-2O10-03180

cR-JAF-2010-03341

CR-JAF-2o10-03411

CR-JAF-2010-03680

CR-JAF-2o10-03989

CR-JAF-2010-04003

CR-JAF-2O10-04018

CR-JAF-2010-04858

CR-JAF-2010-05246

CR-JAF-2O10-05534

CR-JAF-2O10-05688

cR-JAF-2O10-05887

cR-JAF-2O10-07300

cR-JAF-2o10-0797

CR-JAF-2010-08564

CR-JAF-2O1

1-00063

CR-JAF-201

1-00873

CR-JAF-2O1

1-01960 cR-JAF-2O11-02533

CR-JAF-2011-02851

Section 2RS7: Radioloqical

Environmental Monitorinq Proqram Procedures:

SP-04.09, "Environmental Radiological Sample and Land Use Survey Data Collection," Revision 2

DVP-04.01, "JAF Environmental Laboratory Quality Assurance/Quality Control Program," Revision 4

AM-03.03, "Air Particulate Filter Analysis for Gross Beta," Revision 3

AM-03.04, "Radioiodine Cartridge Analysis Using Gamma Spectroscopy," Revision 1

AM-04.04, "Tritium Analysis of Water Samples," Revision 10 Documents:

EA Science and Technology

2010 Nearest Resident Census EA Science and Technology

2010 Mitk Animal Census EA Science and Technology

2010 Garden Census

JAFLO-2009-0089, "RETS/ODCM

Radiological Effluents Organization Condition Report" Focused Assessment Learning Quality Assu ra nce Aud it Repo ft

QA-21 6-2009-JAF-

1, " Chem istry, Effluents.

and Environmental Monitoring" JAF NPP Environmental Laboratory Quality Assurance Report, January 1 through December 31, 2010

EN-CY-102, "Entergy Nuclear Management Manual, Laboratory Analytical Quality Control," Revision 3 Tektronix Certificates of Calibration for Flow Meter Model

AC-250, Numbers 10452, 10436, 12055, 10434, 10872, 10873, 10889, 10871, and 10698 James A. FitzPatrick (JAF) Nuclear Power Plant Annual Radiological Environmental Operations Report, January 1 - December 31, 2010 Attachment

DVP-O1.02, "Offsite Dose Calculation Manual," Revision 11 Selected 2011 Monthly Environmental Sample Results: Milk (April and June); Canal Water (March); Air (April)AREVA Environmental Laboratory

QA Snapshot Self-Assessment, November 2009

Section 4OA2: ldentification

and Resolution of Problems Procedures:

EN-Ll-102, "Corrective Action Process," Revision 16

EN-Ll-119, "Apparent Cause Evaluation (ACE) Process," Revision 11

EN-LI-1 19-01, "Equipment Failure Evaluation," Revision 0

EN-FAP-OP-006, "Operator Aggregate lmpact Index Performance Indicator," Revision 0

EN-OP-1 lT, "Operations Assessments," Revision 3 Condition Reports:

CR-JAF-2o1

1-03394

CR-JAF-201

1-03453 CR-JAF-2011-03462

CR-JAF-2o11-03491

CR-JAF-2011-03517

CR-JAF-2011-03557

CR-JAF-201

1-03699 CR-JAF-2O10-04912

Work Orders: 00'168145

00260441

00262558

0026991 9

00288871

00226615

00253882

00254107

00254293 Section 4OA5: Other Activities Procedures:

CR-JAF-20

1-03772

CR-JAF-2O1

1-03846

CR-JAF-2O1

1-03889

CR-JAF-201

1-04056

CR-JAF-201

1-04090 CR-JAF-2011-04144

CR-JAF-2O11-04208

254824

002551 08

00255131

00256050

00257767

00258129

00258793

00259208

00261300 CR-JAF-2o11-04367

cR-JAF-zo11-Q4378

QR-JAF-2o11-Q4411

CR-JAF-2O11-04470

cR-JAF-2o11-04510

CR-JAF-2011-04736

CR-JAF-2O11-04897

263097

00266823

00271498

00290608

00290609

51101401

51101426

RT-04.14, "Non-REMP

Thermoluminescent Dosimetry (TLD) Program," Revision 3

RP-OPS-0B.01, "Routine Surveys and lnspections," Revision 18 Attachment

LIST OF ACRONYMS

ACE apparent cause evaluation

ADAMS Agencywide

Documents

Access and Management

System ATWS anticipated

transient

without scram CAM continuous

atmospheric

monitoring

CAP corrective

action program CDI condensate

demineralizer

influent

CFR Code of Federal Regulations

CR condition

report CST condensate

storage tank

DBD design basis document

EC engineering

change EDG emergency

diesel generator Entergy Entergy Nuclear Northeast ESOMS electronic

shift operations

management

system ESW emergency

service water oF Fahrenheit

FitzPatrick

James A. FitzPatrick

Nuclear Power Plant HRA high radiation

area ISFSI independent

spent fuel storage installation

IMC inspection

manual chapter IST inservice

test kV kilovolt LCO limiting condition

for operation

LER licensee event report

LPSI low pressure safety injection

MOV motor operated valve

NCV non-cited

violation

NEI Nuclear Energy Institute

NIST National Institute

of Standards

and Technology

NRC Nuclear Regulatory

Commission

NVLAP nationalvoluntarylaboratoryaccreditationprogram

ODCM offsite dose calculation

manual ODMI operational

decision-making

issue PARS Publicly Available

Record PMT post-maintenance

testing

RB reactor building

RBVS reactor building ventilation

system RCIC reactor core isolation

cooling

RCS reactor coolant system

REMP radiological

environmental

monitoring

program

RHR residual heat removal

RPS reactor protection

system RWP radiation

work permit

SGT standby gas treatment

SJAE steam jet air ejector

SLC standby liquid control

SSC structure, system, or component Attachment

ST [[]]

TB [[]]

TLD [[]]

TS [[]]

UFSAR [[]]

URI [[]]

VHRA [[]]

WO A-9 surveillance

test turbine building thermoluminescent

dosimeter tech nical specification

updated final safety analysis report unresolved

item very high radiation

area work order Attachment