IR 05000219/2008009
| ML082660995 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/22/2008 |
| From: | Racquel Powell Division Reactor Projects I |
| To: | Pardee C AmerGen Energy Co, Exelon Generation Co |
| POWELL, R | |
| References | |
| IR-08-009 | |
| Download: ML082660995 (19) | |
Text
UNITED STATES September 22, 2008
SUBJECT:
OYSTER CREEK GENERATING STATION - PROBLEM IDENTIFICATION AND RESOLUTION REPORT 05000219/2008009
Dear Mr. Pardee:
On August 8, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at your Oyster Creek Generating Station. The enclosed inspection report documents the inspection findings, which were discussed with Mr. Timothy Rausch, Site Vice President, and members of his staff at an exit meeting on August 8, 2008.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
There were no findings of significance identified during this inspection. The inspectors concluded that, in general, problems were properly identified, evaluated, and corrected.
AmerGen personnel identified problems and entered them into the Corrective Action Program (CAP) at a low threshold. AmerGen prioritized and evaluated issues commensurate with the safety significance of the issues. The CAP processes and management reviews in place to review issue reports were comprehensive. The team noted, however, that this same level of rigor was not consistently applied when corrective actions for equipment issues were transferred to your work management process (PIMS). In general, corrective actions were effective and implemented in a timely manner. 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 Publically Available Records (PARS) component of the 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/
Raymond Powell, Chief Technical Support and Assessment Branch Division of Reactor Projects Docket Nos. 50-219 License Nos. DPR-16 Enclosure: Inspection Report No. 05000219/2008009 w/Attachment: Supplemental Information cc w/encl:
C. Crane, Executive Vice President, Exelon, Chief Operating Officer, Exelon Generation M. Pacilio, Chief Operating Officer, Exelon T. Rausch, Site Vice President, Oyster Creek Nuclear Generating Station J. Randich, Plant Manager, Oyster Creek Generating Station J. Kandasamy, Regulatory Assurance Manager, Oyster Creek R. DeGregorio, Senior Vice President, Mid-Atlantic Operations K. Jury,Vice President, Licensing and Regulatory Affairs P. Cowan, Director, Licensing B. Fewell, Associate General Counsel, Exelon Correspondence Control Desk, AmerGen Mayor of Lacey Township P. Mulligan, Chief, NJ Dept of Environmental Protection R. Shadis, New England Coalition Staff E. Gbur, Chairwoman - Jersey Shore Nuclear Watch E. Zobian, Coordinator - Jersey Shore Anti Nuclear Alliance P. Baldauf, Assistant Director, NJ Radiation Protection Programs
SUMMARY OF FINDINGS
IR 05000219/2008009; 07/21/2008 - 08/08/2008; AmerGen Energy Company, LLC, Oyster
Creek Generating Station; Biennial Baseline Inspection of the Identification and Resolution of Problems.
This team inspection was performed by three NRC region-based inspectors, and one resident inspector stationed at Oyster Creek. There were no findings or violations identified during this inspection.
Identification and Resolution of Problems The inspectors concluded that AmerGen was generally effective in identifying, evaluating and resolving problems. AmerGen personnel identified problems and entered them into the Corrective Action Program (CAP) at a low threshold. The inspectors determined that, in general, AmerGen appropriately screened issues for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. Causal analyses appropriately considered extent of condition, generic issues and previous occurrences.
Corrective actions for high priority issues were appropriate; however, issues that were forwarded to the work management system (PIMS) for resolution did not consistently receive the same level of rigor and attention that the CAP provided. AmerGen staff exhibited difficulty in following corrective actions through this process and were unable to clearly state how a variety of issues were addressed in PIMS.
AmerGens audits and focused area self-assessments were generally very thorough and probing. The inspectors concluded that AmerGen adequately identified, reviewed, and applied relevant industry operating experience (OE). Based on interviews and other field observations and discussions, the inspectors concluded that site personnel were willing to raise safety issues and to document them in the CAP.
NRC-Identified and Self-Revealing Findings
None.
Licensee-Identified Violations
None.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (PI&R) (Biennial - 71152B)
a. Assessment of the Corrective Action Program (CAP)
Inspection Scope The inspectors reviewed the procedures that describe AmerGens CAP at the Oyster Creek Generating Station (OC). AmerGen personnel identified problems for evaluation and resolution by initiating issue reports (IRs) that were entered into the issue reporting system (Passport). IRs are evaluated for operability, categorized by significance, assigned a level of evaluation and tracked and trended. The Station Operations Committee (SOC) reviews the initial evaluation and adjusts the categorization and investigation class and makes additional changes or clarifications when appropriate.
Issues requiring work are entered into the work management system (PIMS) as action requests (ARs). Work orders (WOs) are developed that are implemented in the work week schedule or during refueling outages.
The inspectors evaluated the process for assigning and tracking issues to ensure they were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspectors interviewed plant staff and management to determine their understanding of, and involvement with, the CAP.
The inspectors reviewed IRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP) to determine if AmerGen personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The inspectors selected items from functional areas that included operations, maintenance, engineering, radiation safety, emergency preparedness, physical security, and oversight programs to ensure that AmerGen appropriately addressed problems identified in these functional areas. The inspectors selected a risk-informed sample of IRs that had been issued since the last NRC PI&R inspection conducted in May 2006.
The inspectors considered risk insights from the stations risk analyses to focus the sample selection and plant tours on risk-significant systems and components.
Inspectors samples focused on, but were not limited to, these systems. The corrective action review was expanded to five years for evaluation of issues associated with the containment spray system and the startup transformers.
The inspectors selected items from other processes at OC to verify that they were appropriately considered for entry into the CAP. Specifically, the inspectors reviewed a sample of ARs in the work management system, operator workaround conditions, operability determinations and WOs.
The inspectors observed daily IR screening meetings, conducted by the SOC and Maintenance Review Committee (MRC), where AmerGen personnel reviewed new IRs for prioritization, investigation class and assignment. The IRs reviewed encompassed the full range of evaluations, including root cause analyses (RCAs), apparent cause evaluations (ACEs), and common cause analyses (CCAs). IRs that were assigned lower levels of significance which did not include formal cause evaluations were also reviewed by the inspectors to ensure they were appropriately classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions (CAs) to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, extent-of-condition reviews and follow up work assignments for selected problems to verify these processes adequately addressed equipment operability and reportability of issues to the NRC.
The inspectors reviewed IRs for adverse trends and repetitive problems to determine whether CAs were effective in addressing broader issues. The inspectors reviewed AmerGens timeliness in implementing CAs and evaluated their actions to prevent recurrence for issues that involved significant conditions adverse to quality. The inspectors also reviewed IRs associated with selected NRC non-cited violations (NCVs)and findings since May 2006 to determine whether AmerGen personnel properly evaluated and resolved issues, including the timeliness and adequacy of corrective actions. The IRs and other documents reviewed, as well as key personnel contacted, are listed in the Attachment.
2. Assessment
Identification of Issues The inspectors concluded that AmerGen personnel identified problems and entered them into the CAP at a low threshold. Most OC departments effectively identified and documented issues in IRs. However, the inspectors noted that the Security Department use of the CAP was below the level that would be expected. Based upon analysis of security related IRs and interviews with security officers (SOs) and the Security Manager, the inspectors determined that this issue appears to be a legacy issue related to the recent change from a contracted security force to an in-house force which occurred in May 2008. Prior to the changeover, SOs would report deficiencies to supervisors who were tasked with documenting the issue into either the contractors corrective action program or the stations CAP. SOs were not tasked with documenting any deficiencies. After the changeover, SOs have been tasked with entering problems directly into the stations CAP. The inspectors interviewed SOs to assess their familiarity with the CAP. Many SOs stated that they were briefed on the use of the CAP by supervisors, but believed that additional training was planned to increase their understanding of the process and how to enter an issue. SOs also indicated that they would willingly identify items of safety or security significance to their supervisor with the expectation that they would be adequately addressed. Although the use of supervisors to enter issues may have been an acceptable practice in the past, AmerGen acknowledged that this old practice is undesirable and expressed the need to have individual SOs enter issues into the CAP. AmerGen initiated IR 00805024 to document this concern.
The inspectors concluded that AmerGen personnel were identifying trends at low levels and did not identify trends or repetitive issues that AmerGen had not self-identified.
Although the descriptions in most IRs was generally good, there were several examples where the subject of the IR was either too general or did not reflect the underlying condition which made trending of similar events and issues challenging. The inspectors noted that many IRs (approximately one-third) did not have a system number assigned.
Although the inspectors determined that this challenged AmerGens staffs ability to trend issues, no deficiencies in trending were identified during the inspection.
Prioritization and Evaluation of Issues The inspectors determined that, in general, AmerGen appropriately prioritized and evaluated issues commensurate with the safety significance of the underlying issue. IRs were initially screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The SOC and MRC were effective at reviewing IRs for significance and adjusting categorization and departmental assignments, when warranted.
The inspectors noted that AmerGens ACEs and RCAs were generally thorough. The inspectors observed a MRC review of an ACE and noted that the members provided insightful comments which were indicative of thorough preparation.
The inspectors assessed AmerGens prioritization and evaluation of the operations procedure change backlog. The backlog of procedure changes for operations has decreased from approximately 720 in 2007 to 320 in 2008. In 2008, there have been about 15 change requests submitted each week with about the same number being resolved. The inspectors sampled five changes and noted that four of them were improperly prioritized as enhancements vice correcting setpoints or procedural steps.
The inspectors evaluated this issue as minor as it has not had an adverse effect on system operation or performance.
The inspectors noted that one of the change requests involved operation of the reactor water cleanup system pumps and valves has been open for 18 months and involved a technical disagreement on system operation between operations and engineering. The inspectors noted, and AmerGen acknowledged, that they do not have a process in place to resolve differing professional views or opinions. AmerGen initiated IR 808546 to document this concern.
Effectiveness of CAs The inspectors concluded that CAs for identified deficiencies were typically timely and adequately implemented. AmerGen conducted in-depth effectiveness reviews for significant issues to determine if CAs were effective in resolving the issue. The inspectors identified a few minor instances where CAs were not fully effective in addressing underlying deficiencies. For significant conditions adverse to quality, the inspectors concluded that AmerGens actions were comprehensive and successful at preventing recurrence.
The inspectors expanded the scope of review to five years during the review of the identification and resolution of issues associated with the containment spray system and the startup transformers. These systems have components where degradation may be age dependent, such as aging of electrical components or having components that may incur degradation due to interactions with raw water. Walkdowns of these systems did not identify any new deficiencies. The inspectors noted that there were very few outstanding deficiencies associated with either system and that actions were underway to either monitor or correct the underlying conditions.
For IRs that involved equipment issues, ARs are placed into the work management system to drive the correction of the identified deficiency. IRs that have been assigned ARs are closed out as complete in the CAP, even if the work required to address the deficiency is not done. The expectation is that any actions taken to address the underlying conditions will be tracked and documented under the AR. Although this is permissible under AmerGen procedures, the inspectors determined that this process makes tracking the timely completion of corrective actions within the CAP challenging.
The number of IRs that are open at any given point in time does not provide a true indication of how successful the station is at resolving corrective actions because, in these instances, the CAP does not track corrective actions beginning to end. For example, IR 772816 was listed as complete and the associated AR was Routed. A status of Routed means that the work has yet to be scheduled. In another example, IR 781438 was listed as complete in the CAP and the associated PIMS AR is Planned but not yet worked. A status of Planned means that the work has been scheduled. This approach can create personal accountability issues because the PIMS AR process does not receive the same management and/or process rigor that IRs do through the CAP. In general, the inspectors noted that plant staff had difficulty showing that corrective actions generated in response to CAP IRs had been completed in a timely manner. The inspectors noted that similar concerns were documented in NRC Inspection Report 05000219/2008003.
In another example, deficiencies (loose keyway, pillow block problem) were identified in the spring of 2007 with the reactor building (RB) crane in WO R2085532. The crane is used to move highly radioactive waste and irradiated fuel in the spent fuel pool.
Documentation in the WO indicated that these deficiencies were to be corrected during the performance of the spring 2008 inspection. These items were not corrected during this inspection and an additional set of deficiencies was identified in IR 761184. The RB crane was characterized in WO R2105552 as being in poor working condition and CAs were scheduled to take place prior to the next refueling outage. These CAs were not scheduled to occur prior to the next heavy load lift. In July 2008, the RB crane malfunctioned while moving a cask that contained highly radioactive components.
Specifically, crane motion stopped while the cask was underwater and there was no change in radiation levels on the refueling floor as a result of this malfunction. The cause of the motion stoppage appeared to be related to limit switch malfunction which was identified during the spring 2008 inspection. AmerGen wrote an IR to acknowledge lack of timely corrective action for this condition. The inspectors reviewed this performance deficiency against the Occupational Radiation Safety cornerstone to determine if a single reasonable minor alteration in circumstances could have led to an unintended increase in worker dose. The inspectors considered a circumstance in which cask motion stopped with the cask out of the water at the worst case location along its intended travel path and determined that there would not have been any significant increase in worker dose. Based on this conclusion, this issue was not considered to be more than minor.
b. Assessment of the Use of Operating Experience 1. Inspection Scope The inspectors reviewed a sample of industry operating experience (OE) issues to confirm that AmerGen evaluated the OE information for applicability to OC and took appropriate actions when warranted. The inspectors reviewed OE documents to determine that AmerGen appropriately considered the underlying problems associated with the issues for resolution via the CAP. The inspectors also observed plant activities to determine if industry OE was considered during the performance of routine and infrequently performed activities. A list of the documents reviewed is included in the to this report.
2. Assessment The inspectors determined that AmerGen appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues. Industry OE was incorporated into the daily routine at OC as part of management meetings, as part of pre-job briefs and as part of pre-evolution briefs. The inspectors assessed that, in general, OE was appropriately applied and lessons learned were effectively communicated and incorporated into plant operations.
c. Assessment of Self-Assessments and Audits 1. Inspection Scope The inspectors reviewed a sample of Quality Assurance (QA) audits, including the most recent audit of the CAP, focused area self-assessments (FASAs), and assessments conducted by independent organizations. These reviews were performed to determine if problems identified through these assessments were entered into the CAP when appropriate, and whether CAs were initiated to address identified deficiencies. A list of documents reviewed is included in the Attachment to this report.
2. Assessment The inspectors concluded that self-assessments, QA audits, and other assessments were generally critical, probing, thorough and effective in identifying issues. The inspectors noted that audits and FASAs were completed in a methodical manner by personnel knowledgeable in the subject. The FASAs were generally comprehensive.
However, the inspectors noted that the FASAs completed by the Security Department did not have external members on the team. AmerGen acknowledged this comment and will ensure that future security FASAs have external members. In general, the actions proposed for identified issues were commensurate with their safety significance.
d. Assessment of Safety Conscious Work Environment 1. Inspection Scope During interviews with AmerGen personnel, the inspectors assessed whether there were issues that could have challenged the free flow of information or other factors that could have resulted in a reluctance to raise safety concerns. The inspectors also assessed whether the plant staff was willing to enter issues into the CAP or raise safety concerns to their management and/or to the NRC. The inspectors interviewed the station employee concerns program investigator (ECI) and representative (ECR) to determine the number and types of issues being raised and entered into the employee concerns program (ECP). The inspectors reviewed a sample of the ECP files to assess the programs effectiveness in addressing potential safety issues.
2. Assessment All persons interviewed demonstrated adequate knowledge of the CAP and ECP. Based on these interviews, the inspectors did not identify any reluctance to raise safety issues or any significant challenges to the free flow of information. The inspectors determined that site personnel were willing to raise safety issues and to document them in the CAP.
4OA6 Meetings, Including Exit
On August 8, 2008, the inspectors presented the inspection results to Mr. T. Rausch, Site Vice President, and to other members of the OC staff. The inspectors verified that no proprietary information is documented in the report.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- J. Dent, Director, Work Management
- J. Dostal, Shift Operations, Superintendent
- S. Dupont, Regulatory Assurance Specialist
- R. Ewart, Security Supervisor
- T. Keenan, Site Security Manager
- J. Kandasamy, Manager, Regulatory Assurance
- G. Ludlam, Director, Training
- P. Orphanos, Director, Operations
- R. Peak, Director, Engineering
- D. Pfeiffer, Manager Nuclear Oversight
- J. Raby, Radiation Protection
- J. Randich, Plant Manager
- T. Rausch, Site Vice President
- H. Ray, Manager, Engineering Programs
- T. Schuster, Manager, Environmental/Chemistry Manager
- T. Sexsmith, Manager Corrective Action Program
- J. Vaccaro, Director, Maintenance
- C. Williams, NSSS System Engineer
Others
- R. Pinney, State of New Jersey, Bureau of Nuclear Engineering
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None