IR 05000219/2016008
| ML16351A000 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/14/2016 |
| From: | Barber S NRC/RGN-I/DRP/PB6 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Kennedy S | |
| References | |
| IR 2016008 | |
| Download: ML16351A000 (17) | |
Text
December 14, 2016
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION -
PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000219/2016008
Dear Mr. Hanson:
On November 18, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at the Oyster Creek Nuclear Generating Station. The NRC inspection team discussed the results of this inspection with Mr. M. Gillin, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
In all of the areas reviewed, the NRC inspectors did not identify any findings or violations of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Silas Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects
Docket Nos.: 50-219 License Nos.: DPR-16
Enclosure:
Inspection Report 05000219/2016008 w/Attachment: Supplementary Information
REGION I==
Docket Nos.
50-219
License No.
Report Nos.
Licensee:
Exelon Nuclear
Facility:
Oyster Creek Nuclear Generating Station
Location:
Forked River, New Jersey
Dates:
October 31, 2016 - November 4, 2016, and
November 14 - 18, 2016
Team Leader:
S. Barber, Senior Project Engineer
Inspectors:
E. Andrews, Resident Inspector N. Floyd, Reactor Inspector
R. Vadella, Project Engineer
Approved By:
Silas R. Kennedy, Chief
Reactor Projects Branch 6
Division of Reactor Projects
SUMMARY
Inspection Report 05000219/2016008; 10/31/16 - 11/4/2016 and 11/14 - 18, 2016,
Oyster Creek Nuclear Generating Station Biennial Baseline Inspection of Problem Identification and Resolution.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
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 prioritized issues commensurate with their safety significance. In most cases, 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 typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.
The inspectors concluded that, in general, 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 generally acceptable.
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 PI -AA-120, Issue Identification and Screening. 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 multiple Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings.
The inspectors selected items from the following functional areas for review:
engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (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, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the safety related electrical and instrument air systems. Additionally, the inspectors reviewed a sample of issue reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into its corrective action program, as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization of a sample of issue reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in October 2014. The inspectors also reviewed issue reports 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 issue reports 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 issue reports 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 instrument air system deficiencies to ensure that they were adequately addressed for this risk significant system.
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 15,900 IRs between January 2015 and October 2016. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging issue reports 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 issue reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program, as appropriate. 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 during this inspection, Exelon personnel promptly initiated issue reports and/or took immediate action to address these 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 issue reports for operability and reportability, categorized the issue reports 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 issue reports reviewed, the inspectors noted that the guidance provided by Exelons corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, 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 did note an observation in Exelons prioritization and evaluation of the following issue:
Categorization of NRC Non-Cited Violations
The inspectors reviewed a sample of 11 IRs associated with previously issued NRC non-cited violations (NCVs) and findings and determined that Exelon did not follow its own procedures for six of these IRs. PI-AA-120, Issue Identification and Screening Process, requires that IRs documenting issues associated with the receipt of an NRC violation or finding be classified with significance level 3. Additional follow-up, such as a work group evaluation or apparent cause evaluation, is required for IRs designated as significance level 3. Six IRs were inappropriately categorized as significance level 4, and did not receive this additional level of scrutiny. This represents a missed opportunity for Exelon to understand the underlying performance issues that resulted in adverse conditions. Exelon documented this performance deficiency in IR 2737186.
The inspectors evaluated the deficiencies noted above for significance in accordance with the guidance in Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. Although the significance level for these six IRs was not properly categorized, the inspectors noted that the underlying technical issues that resulted in the findings or NCVs were adequately addressed. Thus, the inappropriate categorization of these issue reports was considered to be a performance deficiency of minor significance and, therefore, not subject to enforcement action in accordance with NRCs Enforcement Policy.
- (3) Effectiveness of Corrective Actions
The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address selected NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective. The inspectors did observe some observations in Exelons resolution of degraded conditions for the following two issues:
Missed Surveillance Tests
IR 2739733 documented that the completed surveillance tests for Core Spray System 1 Testable Check Valve, Core Spray System 2 Testable Check Valve, and Intermediate Range Monitor Range 9 could not be found and were presumed to be misplaced. This IR also stated that the Core Spray System 1 Testable Check Valve indicated open during the surveillance when the valve was verified shut locally, a potentially non-conservative condition. Although operator logs and a work tracking data base indicated that all three surveillance tests had been satisfactorily completed, the inspectors questioned the operability of these three systems because of a lack of quality assurance records documenting these activities.
The inspectors informed Exelon of these concerns. Subsequently, Exelon produced completed work documentation that showed that the indication for the Core Spray System 1 Testable Check Valve was successfully repaired, and post-maintenance testing was completed satisfactorily. The post-maintenance test for this repair included completing applicable portions of the surveillance test that would have been performed during the outage (i.e., the missed surveillance test). The inspectors reviewed both work documents and considered them to be acceptable. Therefore, there was reasonable assurance that the Core Spray System 1 Testable Check Valve remained operable.
Regarding the other two surveillances, Exelon implemented RM-AA-101-1008, Processing and Storage of Records, Section 4.5, Replacing Lost, Damaged, or Contaminated Documents (Records). This section required reviewing operator logs and incident reports and conducting interviews with individuals who performed, reviewed, and approved the completion of the surveillance tests to verify that the remaining two surveillances were completed satisfactorily. The inspectors reviewed Exelons actions for these two missed surveillance tests and considered them to be acceptable. Exelon entered this issue into the corrective action program as IRs 2742129 and 2742131
The inspectors evaluated this issue for significance in accordance with IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues.
Although three surveillance tests were not adequately documented, the inspectors noted that Exelons documented actions provided reasonable assurance that all three systems remained operable. Thus, the inspectors determined this issue was minor, and, as a result, was not subject to enforcement action in accordance with NRCs Enforcement Policy.
Delayed Corrective Actions for Scram Discharge Volume Valve Vent Valves
In 2012, scram discharge volume (SDV) vent valve, V-15-119, failed during in-service testing. Exelon performed an equipment apparent cause evaluation (EACE) which determined the cause to be the air pressure regulator (APR) not bleeding air as a result of a 2010 modification when an APR with internal soft seats was installed. At that time, Exelon also determined that there were three SDV vent and drain valves with this susceptible design and that the non-safety related pressure regulator classifications should be reevaluated. Subsequently, Exelon generated engineering change request (ECR) 13-00358 to replace the APRs for these three scram discharge vent and drain valves, but only one of these APRs was replaced during the next refueling outage (1R25) in October 2014. Later, in early 2015, an NRC modifications team inspection reviewed these circumstances and issued a non-cited violation (NCV 2015008-02) for untimely corrective actions because Exelon did not restore design conformance for the other SDV vent and drain valves. This violation noted the APRs for the other two valves were not replaced at the first opportunity of sufficient duration, nor was the basis for deferral of corrective actions beyond plant restart from 1R25 documented, reviewed, and approved by site management and/or oversight organizations.
During a recent refueling outage (1R26) in October 2016, Exelon discovered that the SDV drain valve did not have an associated pressure regulator, and therefore, was acceptable per design. The inspectors noted that the pressure regulator replacement for the remaining SDV vent valve was de-scoped from the outage, but Exelon did not explicitly justify the deferral consistent with the operability procedure, OP-AA-108-115, Operability Determinations. The inspectors determined that the failure to replace the remaining SDV vent valve was a performance deficiency that appeared similar to the previous NCV, but with several key exceptions.
Specifically, the inspectors noted that station management did review and approve the deferral of the pressure regulator replacement as documented in the outage scope reduction form 1R26-162 and in a supporting valve scope spreadsheet. Thus, the basis for deferral of corrective actions beyond plant restart from 1R26 was documented, reviewed, and approved by site management; however, not all of the criteria in OP-AA-108-115 were fully addressed. OP-AA-108-115 states, in part, that the justification should address the timing of corrective actions, the identified cause including contributing factors and proposed corrective actions, the existing conditions, and the basis for why the repair or replacement will not be accomplished prior to restart after a planned outage. Although not all of these criteria were satisfied, the inspectors noted that a sufficient number were satisfied to adequately address this issue. Exelon initiated IR 2742750 to document this performance deficiency.
The inspectors evaluated this issue for significance in accordance with IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues.
The inspectors noted that Exelon had an operability evaluation in the original issue report that showed that this non-conforming condition did not adversely impact the plant operation. Although the remaining SDV vent valve was not replaced, its failure would not result in a loss of safety function but merely a loss of redundancy, and therefore would not have a significant impact on plant operations. The inspectors determined this issue was minor, and, as a result, it was not subject to enforcement action in accordance with NRCs Enforcement Policy.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of issue reports associated with review of industry operating experience to determine whether Exelon 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 adequately considered the underlying problems associated with the issues for resolution via its 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.
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. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs.
b. 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, departmental self-assessments, and assessments performed by independent organizations. 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.
Assessment
The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally 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 completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
b. 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 and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees are 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.
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 no significant challenges to the free flow of information.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On November 18, 2016, the inspectors presented the inspection results to Mr. M. Gillin, Plant Manager, 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.
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- G. Stathes, Site Vice President
- M. Gillin, Plant Manager
- M. Arnao, Outage Manager
- A. Beard, Senior Maintenance Program Specialist
- M. Capone, Engineering Manager
- D. Chernesky, Maintenance Director
- J. Clark, Chemistry Manager
- R. Dutes, Regulatory Assurance Specialist
- J. Jimenez, Senior Regulatory Assurance Specialist
- T. Keenan, Site Security Manager
- A. Krukowski, Shift Operations Superintendent (Acting)
- M. McKenna, Regulatory Assurance Manager
- H. Ray, Engineering Senior Manager
- W. Sacareno, Engineering Manager
- S. Schwartz, System Manager
- J. Stanley, Engineering Director
- E. Swain, Shift Operations Superintendent
- T. Trettel, Instrument Air System Manager
- J. Weissinger, Operations Director