IR 05000461/2004008

IR 05000461-04-008, on 10/01/2004 - 12/31/2004; Clinton Power Station, Routine Integrated Inspection Report

ML050250033
Person / Time
Site:	Clinton
Issue date:	01/24/2005
From:	Ring M NRC/RGN-III/DRP/RPB1
To:	Crane C Exelon Generation Co
References
IR-04-008
Download: ML050250033 (34)

Text

ary 24, 2005

SUBJECT:

CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2004008

Dear Mr. Crane:

On December 31, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Clinton Power Station. The enclosed report documents the inspection findings which were discussed on January 13, 2005, with Mr. R. Bement and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and to 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.

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

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62

Enclosure:

Inspection Report No. 05000461/2004008 w/Attachment: Supplemental Information See Attached Distribution

DOCUMENT NAME: E:\Filenet\ML050250033.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII E RIII RIII RIII NAME MRing/trn DATE 01/24/05 OFFICIAL RECORD COPY

REGION III==

Docket No: 50-461 License No: NPF-62 Report No: 05000461/2004008 Licensee: AmerGen Energy Company, LLC Facility: Clinton Power Station Location: Route 54 West Clinton, IL 61727 Dates: October 1 through December 31, 2004 Inspectors: B. Dickson, Senior Resident Inspector C. Brown, Resident Inspector D. Tharp, Resident Inspector R. Skokowski, Senior Resident Inspector, Byron S. Ray, Senior Resident Inspector, Braidwood R. Alexander, Radiation Protection Specialist B. Palagi, Senior Operations Engineer D. Zemel, Illinois Emergency Management Agency Inspector Approved by: M. Ring, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000461/2004008, 10/01/2004 - 12/31/2004, Clinton Power Station. Routine Integrated

Inspection Report.

This report covers a 3-month period of baseline resident inspection and announced baseline inspections on radiation protection and licensed operator requalifications. The inspection was conducted by Region III inspectors and the resident inspectors. No findings of significance were identified. The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self Revealing Findings

Cornerstone: Mitigating Systems

No findings of significance were identified.

Licensee-Identified Violations

No findings of significance were identified.

REPORT DETAILS

Summary of Plant Status

The plant was operated at approximately 95 percent rated thermal power (maintaining maximum electrical output) throughout the inspection period.

1R01 Adverse Weather

a. Inspection Scope

The inspectors verified that the licensee had completed its seasonal preparations for cold weather in a timely manner before the cold weather actually presented a challenge. The inspectors reviewed the licensees completed freezing temperature annual surveillance and verified that it adequately covered risk-significant equipment and ensured that the equipment was in a condition to meet the requirements of Technical Specifications (TSs), the Operations Requirements Manual (ORM), and the Updated Safety Analysis Report (USAR) with respect to protection from low temperatures. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action system by reviewing the associated condition reports (CRs). Based on their importance for availability as mitigating systems, the inspectors conducted more detailed system reviews and walkdowns for the shutdown service water system, the reactor core isolation cooling system, and the emergency diesel generator air intake structure.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

.1 Complete Semi-Annual

a. Inspection Scope

The inspectors conducted a complete system alignment inspection of the Division 1, 2, and 3 emergency diesel generators including the associated fuel oil and air start systems. These systems were selected because of their high risk significance and mitigating systems function. The inspection encompassed the following activities:

Documents reviewed during this inspection are listed in the Attachment.

• Reviewed plant procedures, drawings, and the USAR to identify proper system alignment,

• Reviewed the system valves, instrumentation, and electrical supplies to verify proper alignment, component accessibility, availability, and current material condition,

• Reviewed the CR database to verify that there were no current operability concerns,

• Reviewed open work orders (WOs) to verify that there were no conditions impacting availability and that deficiencies have been identified,

• Reviewed selected system abnormal operating procedures to verify system configuration control, and

• Reviewed operator work-arounds and operator challenges related to the system.

These activities completed one inspection sample and consisted of the following activities:

b. Findings

No findings of significance were identified.

.2 Partial Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of accessible portions of divisions of risk-significant mitigating systems equipment during times when the divisions were of increased importance due to the redundant divisions or other related equipment being unavailable. The inspectors utilized the valve and electric breaker checklists listed at the end of this report to verify that the components were properly positioned and that support systems were lined up as needed. The inspectors also examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors reviewed outstanding work orders and condition reports (CRs) associated with the divisions to verify that those documents did not reveal issues that could affect division function. The inspectors used the information in the appropriate sections of the USAR to determine the functional requirements of the systems. The documents listed at the end of this report were also used by the inspectors to evaluate the following.

• Reactor core isolation cooling (RCIC) system in anticipation of maintenance on the high pressure core spray system;

• Residual heat removal (RHR) B during Division 1 low pressure emergency core cooling systems outage; and

• Low pressure core spray system (LPCS) during Division 2 RHR systems outage.

These activities completed three samples.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of fire fighting equipment, the control of transient combustibles and ignition sources, and on the condition and operating status of installed fire barriers. The inspectors selected fire areas for inspection based on their overall contribution to internal fire risk, as documented in the Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate a plant transient, or their impact on the licensees ability to respond to a security event. The inspectors used the documents listed at the end of this report to verify that fire hoses and extinguishers were in their designated locations and available for immediate use, that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits, and that fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action program.

The inspectors reviewed portions of the licensees Fire Protection Evaluation Report (FPER) and the USAR to verify consistency in the documented analysis with installed fire protection equipment at the station.

The inspectors completed two samples by inspecting the following areas:

• Fire Zones D-4a, 5a, 6a, diesel generator (DG) rooms at elevation 737 feet; and

• Fire Zones D-4b, 5b, 6b, DG fuel oil day tank rooms at elevation 737 feet.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors verified that flooding mitigation plans and equipment were consistent with the design requirements and risk analysis assumptions. The inspectors reviewed USAR Section 3.4.1 for internal flooding events and reviewed condition reports and work orders on the following:

• Division 2 emergency core cooling systems (RHR B and C) and RCIC rooms flood protection measures while performing work on RHR A and LPCS systems.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operators Requalification Training Activities

a. Inspection Scope

The inspectors reviewed licensed-operator requalification training (LORT) to evaluate operator performance in mitigating the consequences of a simulated event, particularly in the areas of human performance. The inspectors evaluated operator performance attributes which included communication clarity and formality, timely performance of appropriate operator actions, appropriate alarm response, proper procedure use and adherence, and senior reactor operator oversight and command and control.

Crew performance in these areas was compared to licensee management expectations and guidelines as presented in the following documents:

• OP-AA-101-111, Roles and Responsibilities of On-Shift Personnel, Revision 001;

• OP-AA-102-102, Operator Rounds, Revision 004;

• OP-AA-103-102, Watchstanding Practices, Revision 003;

• OP-AA-104-101, Communications, Revision 001; and

• OP-AA-106-101, Significant Event Reporting, Revision 004 In particular, the inspectors observed simulator dynamic exam ESG-LOR-69, Revision 01a, which included internal flooding, suppression pool low level, plant blow down, and an ATWS [anticipated trip without scram] transient. The inspectors also assessed the performance of the training staff evaluators involved in the requalification process. For any weaknesses identified, the inspectors observed that the licensee evaluators also noted the issues and discussed them in the critique at the end of the session. The inspectors verified all issues were captured in the training program and licensee corrective action process.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

.2 Annual Operating Test Results

a. Inspection Scope

The inspector reviewed the overall pass/fail results of individual Job Performance Measure (JPM) operating tests, and simulator operating tests (required to be given per 10 CFR 55.59(a)(2)) administered by the licensee during calender year 2004. The overall results were compared with the significance determination process in accordance with NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP).

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

The inspectors reviewed the effectiveness of the licensees maintenance efforts in implementing the maintenance rule (MR) requirements, including a review of scoping, goal-setting, performance monitoring, short and long-term corrective actions, and current equipment performance problems. These systems were selected based on their designation as risk significant under the MR, or being in the increased monitoring (MR category (a) (1)) group. In addition, the inspectors interviewed the system engineers and maintenance rule coordinator. The inspectors also reviewed condition reports and associated documents for appropriate identification of problems, entry into the corrective action system, and appropriateness of planned or completed actions.

The documents reviewed are listed at the end of the report. The inspectors completed two samples by reviewing the following:

• Pseudo-system 89, secondary containment monitoring.

• High pressure core spray system.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors observed the licensees risk assessment processes and considerations used to plan and schedule maintenance activities on safety-related structures, systems, and components particularly to ensure that maintenance risk and emergent work contingencies had been identified and resolved. The inspectors completed four samples by assessing the effectiveness of risk management activities for the following work activities or work weeks:

• Troubleshooting of an emergent failure of direct current power to components of the Division 2 diesel generator;

• High pressure core spray planned maintenance with highly elevated risk, including walking down protected equipment and reviewing contingency plans;

• Bus 1A 6.9 kV breaker swap (WO 00018521); and

• Division 4 battery charger emergent work.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following operability determinations and evaluations affecting mitigating systems to determine whether operability was properly justified and the component or system remained available such that no unrecognized risk increase had occurred.

The inspectors completed five samples of operability determinations and evaluations by reviewing the following:

• Issues with instantaneous trip values for the high pressure core spray water leg pump molded case circuit breaker;

• Standby gas treatment (SBGT) B room cooler;

• Operability Evaluation 197833, Division 3 Degraded Voltage Time Delay TS Allowable Value;

• High pressure core spray water-leg pump making an unusual noise; and

• Operability Evaluation 219491-03, Division 1 shutdown service water piping and components were classified as Safety Class O [other] vice ASME,Section III, Class 3.

b. Findings

No findings of significance were identified.

1R16 Operator Work-Arounds

a. Inspection Scope

The inspectors reviewed the licensees work-around list and interviewed operators to identify any potential effects on the functionality of mitigating systems or human reliability in responding to an initiating event caused by an operator work-around. The inspectors utilized Procedure OP-AA-102-103, Operator Work-Around Program, Revision 1, during the review.

The inspectors completed one sample by reviewing the operator actions for RHR B/C water leg pump discharge pressure reading high on the RHR C pump discharge pressure instrumentation.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post maintenance testing (PMT) activities associated with maintenance or modification of important mitigating, barrier integrity, and support systems that were identified as risk significant in the licensees risk analysis. The inspectors reviewed these activities to verify that the post maintenance testing was performed adequately, demonstrated that the maintenance was successful, and that operability was restored. During this inspection activity, the inspectors interviewed maintenance and engineering department personnel and reviewed the completed post maintenance testing documentation. The inspectors used the appropriate sections of the TS and USAR, as well as the documents listed at the end of this report, to evaluate this area.

The inspectors completed two samples by observing and evaluating the tests subsequent to the following activities:

• Standby gas treatment system B after system maintenance; and

• Residual heat removal system A pump discharge check valve after maintenance.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors witnessed selected surveillance testing and/or reviewed test data to verify that the equipment tested using the surveillance procedures met the TS, the ORM, the USAR, and licensee procedural requirements, and demonstrated that the equipment was capable of performing its intended safety functions. The activities were selected based on their importance in verifying mitigating systems capability and barrier integrity. The inspectors used the documents listed at the end of this report to verify that the testing met the frequency requirements, that the tests were conducted in accordance with the procedures, including establishing the proper plant conditions and prerequisites, that the test acceptance criteria were met, and that the results of the tests were properly reviewed and recorded. In addition, the inspectors interviewed operations, maintenance, and engineering department personnel regarding the tests and test results.

The inspectors completed two samples by evaluating the following surveillance tests:

• Division 2 emergency diesel generator overspeed trip test; and

• Drywell leakage determination.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed and evaluated the following temporary plant modifications on risk-significant equipment:

The inspectors reviewed these temporary plant modifications to verify that the instructions were consistent with applicable design modification documents and that the modifications did not adversely impact system operability or availability. The inspectors interviewed operations, engineering, and maintenance personnel, as appropriate, and reviewed the design modification documents and the 10 CFR 50.59 evaluations against the applicable portions of the USAR. The documents listed at the end of this report were also used by the inspectors to evaluate this area.

The inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified temporary modification problems were being entered with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for temporary modification related issues documented in selected condition reports. The condition reports are listed at the end of this report.

The inspectors completed two inspection samples by reviewing the following temporary modifications:

• Change LPCS and LPCI internal vessel line breakage setpoints; and

• Install Astromed recorder on Division 4 battery charger.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the emergency response activities associated with the 2004 Off-Year Exercise (Earthquake results in flooding in RHR room) conducted on October 13, 2004. Specifically, the inspectors verified that the emergency classification and simulated notifications were properly completed, and that the licensee adequately critiqued the training. Additionally, the inspectors observed licensee activities during the drill in the Technical Support Center.

These activities constituted one inspection sample.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Review of Licensee Performance Indicators for the Occupational Exposure

Cornerstone

a. Inspection Scope

The inspectors reviewed the licensees reporting of occupational exposure control cornerstone performance indicator (PI) occurrences to determine whether or not the conditions surrounding the PI occurrences had been evaluated and identified problems had been entered into the corrective action program for resolution. For the time period of the 4th Quarter 2003 through the 2nd Quarter 2004, the licensee identified one locked high radiation area occurrence under the Occupational Exposure Control Effectiveness PI which occurred in February 2004 (see Inspection Report 05000461/2004002, Section 2OS1.1).

This review represented one inspection sample.

b. Findings

No findings of significance were identified.

.2 Problem Identification and Resolution

a. Inspection Scope

As discussed in Section 2OS1.1, for the time period of the 4th Quarter 2003 through the 2nd Quarter 2004, the licensee identified one locked high radiation area occurrence under the Occupational Exposure Control Effectiveness PI. As such, the inspectors reviewed licensee root cause evaluation for that PI event to determine if the event involved dose rates greater than 25 rem per hour at 30 centimeters, or greater than 500 rad per hour at 1 meter. Barriers were evaluated for failure and to determine if there were any barriers left to prevent personnel access.

This review represents one inspection sample.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

.1 Inspection Planning

a. Inspection Scope

The inspectors reviewed the calendar years 2002 and 2003 Annual Effluent Reports to verify that the program was implemented as described in Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual (ODCM) and to determine if ODCM changes were made in accordance with Regulatory Guide 1.109 and NUREG-0133. The inspectors reviewed the Annual Effluent Reports and ODCM, to determine if any changes to the design and/or operation of the radioactive waste systems changed the dose consequence to the public. The inspectors also reviewed technical and/or 10 CFR 50.59 evaluations performed, when required, for any such modifications and determined whether radioactive liquid and gaseous effluent radiation monitor setpoint calculation methodology changed since completion of the modifications. The inspectors determined if anomalous results reported in the current Annual Effluent Reports, if any, were adequately resolved.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.2 Onsite Inspection - Walkdown of Effluent Control Systems, System/Program

Modifications, Air Cleaning System Surveillances, and Instrument Calibrations

a. Inspection Scope

The inspectors walked down the major components of the gaseous and liquid release systems (e.g., radiation and flow monitors, demineralizers and filters, tanks, and vessels) to observe current system configuration with respect to the description in the Updated Safety Analysis Report (USAR), ongoing activities, and to assess equipment material condition.

The inspectors reviewed the licensees technical justification for any changes made by the licensee to the ODCM, as well as to the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection to determine whether the changes affected the licensees ability to maintain effluents as-low-as-reasonably-achievable and whether changes made to monitoring instrumentation resulted in non-representative monitoring of effluents.

The inspectors reviewed air cleaning system surveillance test results to ensure that the system was operating within the licensees acceptance criteria. Specifically, the inspectors reviewed the most recent results of the Ventilation Filter Testing Program for the Control Room Ventilation and Standby Gas Treatment Systems to verify that test methodology, frequency and test results met Technical Specification requirements.

The inspectors reviewed and discussed the test results of in-place high efficiency particulate air (HEPA) and charcoal adsorber penetration tests, laboratory tests of charcoal adsorber methyl iodide penetration, and in-place combined HEPA filter and charcoal adsorber train pressure drop tests for the system with radiation protection and system engineering staff.

The inspectors reviewed records of instrument calibrations performed since the last inspection for each point-of-discharge effluent radiation monitor and flow measurement device, and reviewed any completed system modifications and the current effluent radiation monitor alarm setpoint values for conformance with RETS/ODCM requirements. These included:

• Plant Service Water Process Radiation Monitor (PR036) and Flow Rate Device (PR052);

• Radioactive Waste Liquid Discharge Process Radiation Monitor (PR040);

• Station Heating, Ventilation, and Air Conditioning (HVAC) Process Radiation Monitor (PR001) and Flow Rate Device (PR051-151-6);

• Standby Gas Treatment System (SGTS) Process Radiation Monitor (PR004)and Flow Rate Device (PR051-151-1);

• HVAC Accident Range Monitor (PR008); and

• SGTS Accident Range Monitor (PR012).

The inspectors also reviewed calibration records of radiation measurement (i.e.,

chemistry counting room) instrumentation associated with effluent monitoring and release activities and the quality control records for those instruments.

These reviews represented four inspection samples.

b. Findings

No findings of significance were identified.

.3 Onsite Inspection - Effluent Release Packages, Abnormal Releases, Dose

Calculations, and Laboratory Quality Control and Assurance

a. Inspection Scope

As the licensee has reported that zero radioactive liquid effluents were released since 1993 (and thus no public dose contributions from station liquid effluents), the inspectors were unable to review any current radioactive liquid waste release permits. In lieu of these reviews, the inspectors evaluated the physical and administrative controls employed by the licensee to ensure that radioactive liquid effluents have not and are not inadvertently released from the station.

Though there were no routine batch radioactive gaseous releases conducted during the on-site inspection, the inspectors reviewed several weekly continuous radioactive gaseous effluent release permits, including the projected doses to members of the public, to verify that appropriate treatment equipment was used and that the radioactive gaseous effluent was processed and released in accordance with RETS/ODCM and procedure requirements.

The licensee did not identify any abnormal releases, or releases made with inoperable effluent radiation monitors, since the last inspection in this area. As such, the inspectors were unable to review the licensees actions for such releases.

The inspectors reviewed a selection of monthly, quarterly, and annual dose calculations to ensure that the licensee properly calculated the offsite dose from radiological effluent releases and to determine if any annual RETS/ODCM (i.e., Appendix I to 10 CFR Part 50 values) limits were exceeded.

The inspectors reviewed the results of the interlaboratory comparison program to verify the quality of radioactive effluent sample analyses performed by the licensee. The inspectors reviewed the licensees quality control evaluation of the interlaboratory comparison test and associated corrective actions for any deficiencies identified. The inspectors reviewed the licensees assessment of any identified bias in the sample analysis results and the overall effect on calculated projected doses to members of the public. In addition, the inspectors reviewed the results from the licensees Nuclear Oversight (quality assurance) audits to determine whether the licensee met the requirements of the RETS/ODCM and 10 CFR Part 20.

These reviews represented four inspection samples.

.4 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed any available licensee self-assessments, audits, and Special Reports related to the radioactive effluent treatment and monitoring program since the last inspection to determine if identified problems were entered into the corrective action program for resolution. The inspectors also verified that the licensee's self-assessment program was capable of identifying repetitive deficiencies or significant individual deficiencies in problem identification and resolution.

The inspectors also reviewed corrective action reports from the radioactive effluent treatment and monitoring program since the previous inspection, interviewed staff, and reviewed documents to determine if the following activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk:

• Initial problem identification, characterization, and tracking;

• Disposition of operability/reportability issues;

• Evaluation of safety significance/risk and priority for resolution;

• Identification of repetitive problems;

• Identification of contributing causes;

• Identification and implementation of effective corrective actions;

• Resolution of Non-Cited Violations (NCVs) tracked in the corrective action system; and

• Implementation/consideration of risk significant operational experience feedback.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

To perform a periodic review of performance indicator (PI) data to determine its accuracy and completeness.

Cornerstones: Mitigating Systems, Barrier Integrity

.1 Reactor Safety Strategic Area

a. Inspection Scope

The inspectors sampled the licensees submittals for performance indicators (PIs) and periods listed below. The inspectors used PI definitions and guidance contained in Revision 2 of Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, to verify the accuracy of the PI data. The following PI was reviewed:

• RHR Unavailability

• Reactor Coolant System (RCS) Specific Activity The inspectors reviewed the licensees assessment of its performance indicator for RCS specific activity by reviewing Chemistry Department records and selected isotopic analyses (October 2003 through June 2004) to verify that the greatest Dose Equivalent Iodine (DEI) value obtained during those months corresponded with the value reported to the NRC. The inspectors also reviewed selected DEI calculations to verify that the appropriate conversion factors were used in the assessment as required by Technical Specifications. Additionally, on November 3, 2004, the inspectors observed a chemistry technician obtain, prepare, and analyze a reactor coolant sample for DEI to verify adherence with licensee procedures for the collection and analysis of reactor coolant system samples.

These reviews represented two inspection samples.

.2 Radiation Protection Strategic Area

a. Inspection Scope

The inspectors sampled the licensees submittals for performance indicators (PIs) and periods listed below. The inspectors used PI definitions and guidance contained in Revision 2 of Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, to verify the accuracy of the PI data. The following PIs were reviewed:

• Occupational Exposure Control Effectiveness; and

• RETS/ODCM Radiological Effluent.

The inspectors previously reviewed the one locked high radiation area occurrence under the Occupational Exposure Control Effectiveness PI which occurred in February 2004 (see Inspection Report 05000461/2004002, Section 2OS1.1). Since no additional reportable events were identified by the licensee for the 4th Quarter 2003 through 2nd Quarter 2004, the inspectors compared the licensees data with the corrective action program database and the radiological controlled area exit electronic dosimetry transaction records for these time periods, to verify that there were no unaccounted for occurrences in the PI. Additionally, the inspectors conducted walkdowns of accessible locked high radiation areas and very high radiation area entrances to verify the adequacy of controls in place for these areas.

Since no reportable RETS/ODCM radiological effluent PI occurrences were identified by the licensee for the 4th Quarter 2003 through 2nd Quarter 2004, the inspectors compared the licensees data and reviewed corrective action documents generated during the time period to identify any potential occurrences such as unmonitored, uncontrolled or improperly calculated effluent releases that may have impacted offsite dose. Also, concurrent with the reviews discussed in Section 2PS1.3 of this report, the inspectors evaluated the licensees methods for determining offsite dose and selectively verified that liquid and gaseous effluent release data and associated offsite dose calculations performed since this indicator was last reviewed were accurate.

These reviews represented two inspection samples.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Review of Prompt Investigations for Trends, Rigor, and Common-Cause Attributes Introduction The inspectors noted a slight increase in the number of plant issues involving poor human performance and inadequate configuration control. Some of these issues resulted in prompt investigations and apparent cause evaluations being performed by the licensee. The inspectors selected four issue reports (IR) with approved prompt investigations from June 2004 through December 2004 for a review of the licensees problem identification and resolution program.

a. Inspection Scope

The inspectors reviewed the IRs and the associated prompt investigations for any discernible trends, common-cause attributes, and lack of rigor. The IRs were as follows:

• IR 264698, Division 2 Diesel Generator Lockout Relay Activated During Troubleshooting, dated October 21, 2004;

• IR 260605, Auto Start of Division 2 Shutdown Service Water Pump, dated October 15, 2004;

• IR 240212 Steam Bypass Valve Electro-hydraulic Control Pump Breaker Discovered to be Tripped, dated August 3, 2004; and

• IR 269291, Reactor Water Cleanup Pump Both Tripped, dated November 3, 2004.

The inspectors reviewed the above IRs and the associated prompt investigations to verify that the licensees identification of the problems were complete, accurate, and timely, and that the consideration of extent of condition review, generic implications, common cause, and previous occurrences was adequate. The inspectors also considered the licensees evaluation and disposition of performance issues, evaluation and disposition of operability issues, and application of risk insights for prioritization of issues.

These reviews completed one inspection sample.

b. Findings

No findings of significance were identified. The inspectors did not identify a trend or common-cause for the issues documented by the selected IRs. Two IRs involved human performance issues by operators, both in the field and in the control room. The others were caused by equipment failures. The inspectors reviewed the proposed corrective actions for the selected IRs to ensure that generic implications were addressed and that the corrective actions were appropriately focused on correcting the identified problems.

4OA3 Event Follow-up

(Closed) LER 05000461/2004005-00: Automatic Start of Division 2 Shutdown Service Water Pump Due to Unknown

Cause.

On October 6, 2004, the plant was in Mode 1 with reactor power at 95 percent (which is the maximum power achievable under the authorized power uprate). A planned maintenance outage was in progress for the Division 1 emergency diesel generator (EDG). Several systems were in a protected status due to the EDG outage including the Divisions 2 and 3 shutdown service water (SX) systems. The Division 1 SX system was out of service and Divisions 2 and 3 SX system pumps were in standby; plant service water (WS) was providing steady pressure to Divisions 2 and 3 SX through crosstie piping. Operators were securing from a flush of the Divisions 2 and 3 EDG heat exchangers for corrosion prevention when various alarms in the main control room (MCR) indicated the Division 2 SX pump had automatically started unexpectedly. An operator was dispatched to the SX system equipment and verified proper operation of the equipment. In the MCR, operators observed various alarms for the auto-start, including one for a low-pressure condition in the SX system. A prompt investigation was initiated including identifying the location of workers in the plant and their activities.

No plant activity was in progress that could have caused the automatic start of the Division 2 SX pump. Condition Report 260905 was initiated to investigate the cause of the automatic pump start and to identify corrective actions.

The Division 2 SX system remained operable during and after the event based on the system responding as expected to the valid low pressure signal. No automatic or manually initiated safety-system responses were necessary to place the plant in a safe and stable condition. No inoperable equipment or components directly affected this event. A root cause could not be determined for the auto-start of the Division 2 SX pump. The cause investigation identified that a low-pressure condition occurred in the SX system, most likely caused by an operator closing the WS to SX crosstie valve, resulting in the auto-start of the SX pump. The cause investigation included:

investigating operator performance; reviewing other plant activities in progress at the time of the event; completing a troubleshooting plan for components, logic, and controls having a potential to cause an auto-start of the Division 2 SX pump; and completing a failure analysis on the hand-switch for the WS to SX system crosstie valve due to industry operating experience. No equipment deficiencies were found.

Corrective actions included replacing the hand-switch for the WS to SX crosstie valve as a precaution, placing the EDG flushing activities on the plant schedule, having the operators demonstrate proper peer and self checking activities, and placing a hard plastic protective cover over the crosstie valve hand switch. The LER was reviewed by the inspectors and no findings of significance were identified. This LER is closed.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. R. Bement and other members of licensee management at the conclusion of the inspection on January 13, 2005. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings

Interim exits were conducted for:

• Radiation Protection (RETS/ODCM) inspection with Mr. M. McDowell on November 5, 2004.

• Annual NRC Licensed Operator Requalification examination with Mr. M. Baetz, Licensed Operator Requalification Training Group Lead, on December 29, 2004, via telephone.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Baetz, Licensed Operator Requalification Training Group Lead

R. Bement, Site Vice President

R. Campbell, REMP/RETS

W. Carsky, Shift Operations Superintendent

R. Coon, Nuclear Oversight Manager

J. Cunningham, Work Management Director

R. Davis, Radiation Protection Director

J. Domitrovich, Maintenance Director

R. Frantz, Regulatory Assurance Representative

M. Hiter, Access Control Supervisor

W. Iliff, Regulatory Assurance Director

J. Madden, Chemistry Manager

M. McDowell, Plant Manager

R. Peak, Site Engineering Director

D. Schavey, Operations Director

T. Shortell, Training Manager

C. Williamson, Security Manager

LIST OF ITEMS

Opened and Closed

None

Discussed

None Attachment