IR 05000219/2014008
| ML14352A355 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/18/2014 |
| From: | Silas Kennedy NRC/RGN-I/DRP/PB6 |
| To: | Pacilio J Exelon Nuclear |
| kennedy, sr | |
| References | |
| IR 2014008 | |
| Download: ML14352A355 (17) | |
Text
ber 18, 2014
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - NUCLEAR REGULATORY COMMISSION PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000219/2014008
Dear Mr. Pacilio:
On November 21, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Nuclear Generating Station. The enclosed report documents the inspection results, which were discussed on November 21, 2014, with Mr. G. Stathes, Site Vice President, and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspectors did not identify any findings during this inspection. The inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon, in general, prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were implemented in a timely manner. Lessons learned from industry operating experience were effectively reviewed and applied when appropriate. Additionally, the inspectors concluded that self-assessments and audits reviewed during the inspection were critical, thorough, and effective in identifying issues.
In accordance with Title 10 Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos. 50-219 License Nos. DPR-16
Enclosure:
Inspection Report 05000219/2014008 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-219 License No. DPR-16 Report No. 05000219/2014008 Licensee: Exelon Generation Company, LLC Facility: Oyster Creek Nuclear Generating Station Location: Forked River, NJ Dates: November 3 through 21, 2014 Team Leader: Thomas Setzer, Senior Project Engineer Inspectors: Elizabeth Andrews, Project Engineer Joseph DeBoer, Project Engineer Joseph Schoppy, Jr., Senior Reactor Inspector Approved by: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY
IR 05000219/2014008; 11/03/14 - 11/21/14; Oyster Creek Nuclear Generating Station; Biennial
Baseline Inspection of Problem Identification and Resolution.
This NRC team inspection was performed by four regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.
Problem Identification and Resolution The inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and in general, prioritized issues commensurate with their safety significance. Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.
The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Oyster Creek operations. In addition, based on those items selected for review, the inspectors determined that Exelons self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues, nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described Exelons corrective action program at Oyster Creek. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 Code of Federal Regulations 50, Appendix B, Criterion XVI, Corrective Action, and Exelon procedure PI-AA-125, Corrective Action Program Procedure. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed issue reports (IRs) selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings. The inspectors selected items from the following functional areas for review: Maintenance Rule program, engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and radiation protection.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, and periodic trend reports. The inspectors completed field walkdowns of various safety-related systems on site. Additionally, the inspectors reviewed a sample of IRs written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of IRs issued since the last NRC biennial Problem Identification and Resolution inspection completed in August 2012. The inspectors also reviewed IRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly 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 to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed Exelons completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of IRs associated with selected non-cited violations and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to average power range and intermediate range monitors; the emergency service water corrosion control program; and the emergency diesel generators.
b.
Assessment
- (1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the corrective action program at a low threshold. Exelon staff at Oyster Creek initiated approximately 19,000 issue reports between August 2012 and October 2014. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging IRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in IRs. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated IRs and took immediate action to address the issues.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
Exelon screened IRs for operability and reportability, categorized the IRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of IRs reviewed, the inspectors noted that the guidance provided by Exelon corrective action program implementing procedures appeared sufficient to ensure consistency in the categorization of issues. However, the inspectors identified 20 IRs that were not categorized in accordance with the guidance established by PI-AA-120, Issue Identification and Screening Process, Attachment 2.
Twelve of these twenty IRs were classified as significance level 4, but in accordance with the guidance in PI-AA-120, Attachment 2, the IRs should have been classified as significance level 3. These 12 IRs were related to two of the areas listed in Attachment 2: foreign material found or left in plant systems, and unplanned increases in online risk by one color. The remaining eight IRs were classified as significance level 5, but should have been classified as significance level 4. Exelon procedure PI-AA-120 defines significance level 5 issues as enhancements. The inspectors, however, determined that these eight IRs described conditions that were not enhancements but instead, were low level problems or conditions adverse to quality that the procedure required to be classified as significance level 4.
The inspectors determined that these incorrect categorizations were performance deficiencies; however, they were minor because the difference in categorization only reduced the level of management review for the completed corrective actions.
Additionally, the inspectors reviewed the corrective actions completed for each of these IRs and did not identify concerns with the adequacy of the actions taken to correct the identified issues. Exelon initiated IRs 2407950, 2414855, and 2408361 to address this concern.
The inspectors determined that operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusion.
Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors identified the following example where four failures of electromagnetic relief valve (EMRV)thermocouples were not properly evaluated in accordance with the Exelon Maintenance Rule program.
Oyster Creeks EMRVs have both thermocouples and acoustic monitoring devices installed that provide operators redundant position indication for an EMRV (open or closed). Failures of thermocouples and acoustic monitors are tracked within Exelons Maintenance Rule program in accordance with Exelon procedure ER-AA-310-1004, Maintenance Rule - Performance Monitoring. If both a thermocouple and an acoustic monitor are inoperable during a common period, then the Exelon Maintenance Rule program classifies this as a Maintenance Rule Functional Failure (MRFF) because the EMRV position indication would be lost. Failure of either a thermocouple or an acoustic monitor is considered a Condition Monitoring Failure (CMF). Exelon uses CMFs to monitor and trend the performance of in-scope components, but a CMF in and of itself does not represent a failure in which the Maintenance Rule function or safety function was lost.
The inspectors identified four instances over the past two years (IRs 1460383, 1500241, 1600245, and 2405975) where the EMRV thermocouples were identified as inoperable but were not classified as CMFs in accordance with ER-AA-310-1004. The inspectors determined that this was a performance deficiency, but it was screened as minor because in each of these four instances the associated acoustic monitors remained operable and, therefore, the safety function was not lost. In addition, the inspectors also confirmed that in each case appropriate and timely corrective actions were taken to restore the thermocouple to operable status. Exelon entered this issue into the corrective action program (2413117).
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of IRs associated with review of industry operating experience to determine whether Exelon personnel appropriately evaluated the operating experience information for applicability to Oyster Creek and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program.
In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b.
Assessment The inspectors determined that Exelon appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, focused area self-assessments, and check-in self-assessments performed by Exelon. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
b. Assessment The inspectors concluded that focused area self-assessments, check-in self-assessments, and audits were critical, thorough, and effective in identifying issues.
The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon staff completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. The station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Oyster Creek. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate.
b. Assessment During interviews, Oyster Creek staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and there were not significant challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On November 21, 2014, the inspectors presented the inspection results to Mr. G. Stathes, Site Vice President, and other members of the Oyster Creek staff.
The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Brown, System Manager
- D. Doran, System Manager
- J. Dostal, Plant Manager
- M. Ford, Director, Operations
- E. Irizarry, Plant Operator
- K. Paez, Regulatory Assurance Specialist
- C. Rickets, System Manager (EDGs)
- B. Shehata, ECP Coordinator
- E. Swain, Shift Operations Superintendent
- L. Velez, Maintenance Rule Coordinator
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
None