IR 05000220/2007006

IR 05000220-07-006, 05000220-07-006, on Nine Mile Point Nuclear Station, Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML072150284
Person / Time
Site:	Nine Mile Point
Issue date:	08/03/2007
From:	Mel Gray Division Reactor Projects I
To:	Polson K Nine Mile Point
Gray M, RI/DRP/TSAB/610-337-5209
References
IR-07-006
Download: ML072150284 (16)

Text

August 3, 2007

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000220/2007006 AND 05000410/2007006

Dear Mr. Polson:

On June 28, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Nine Mile Point Nuclear Power Station (NMPNS) Units 1 and 2. The enclosed report documents the inspection results, which were discussed with you and members of your staff on June 28, 2007.

This inspection examined 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. The inspection involved examination of selected procedures and representative records, observations of activities, interviews with personnel and walkdowns of selected plant areas.

There were no findings of significance identified during this inspection. On the basis of the sample selected for review, the inspection team concluded that NMPNS was generally effective in the identification, evaluation and resolution of problems.

In accordance with 10 CFR 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 Publically Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mel Gray, Chief Technical Support and Assessment Branch Division of Reactor Projects Docket Nos.

50-220, 50-410 License Nos. DPR-63, NPF-69

Mr. Enclosure:

Inspection Report 05000220/2007006 and 05000410/2007006 w/Attachment:

Supplemental Information cc w/encl:

M. J. Wallace, President, Constellation Generation J.M. Heffley, Senior Vice President and Chief Nuclear Officer C. W. Fleming, Esquire, Senior Counsel, Constellation Energy Group, LLC M. J. Wetterhahn, Esquire, Winston and Strawn M. Balboni, Deputy Secretary, New York State Energy, Research, and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority P. D. Eddy, Electric Division, NYS Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Supervisor, Town of Scriba T. Judson, Central NY Citizens Awareness Network D. Katz, Citizens Awareness Network C. Adrienne Rhodes, Chairman and Executive Director, State Consumer Protection Board

M

SUMMARY OF FINDINGS

IR 05000220/2007006 and 05000410/2007006; 06/11/2007 - 06/28/2007; Nine Mile Point

Nuclear Station, Units 1 and 2; biennial baseline inspection of the identification and resolution of problems.

This team inspection was performed by two region-based and two resident inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Overall, the inspection team determined that the Corrective Action Program (CAP) at Constellations NMPNS was generally effective in the identification, evaluation, and resolution of problems. The inspection team determined that NMPNS typically identified problems and placed them in the CAP. The inspection team identified that operating experience was utilized and considered at NMPNS, although certain issues at Unit 1 were not fully assessed in all aspects.

The inspection team noted that NMPNS was effective in conducting root cause and apparent cause evaluations and effectively resolved most problems categorized as more significant.

Based on interviews, observations of plant activities, reviews of the CAP and the Employees Concerns Program, the inspection team determined that site personnel were willing to raise safety issues.

NRC Identified and Self-Revealing Findings

None.

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Assessment of the Corrective Action Program

(1) Inspection Scope The inspection team reviewed the procedures describing Constellations Corrective Action Program (CAP) at NMPNS Units 1 and 2. Constellation identified problems for evaluation and resolution by initiating condition reports (CRs) that were entered into the condition reporting system. The CRs were subsequently screened for operability, categorized by significance (1 through 4),and assigned for further evaluation and resolution.

The inspection team evaluated the methods for assigning and tracking issues to ensure that issues 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 inspection team interviewed plant staff and management to determine the staffs understanding of and involvement with the CAP. The CRs and other documents reviewed, as well as key personnel contacted, are listed in the Attachment to this report.

The inspection team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The inspection team selected items from the chemistry, emergency preparedness, engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure that Constellation appropriately addressed problems identified in each functional area.

The inspection team selected a risk-informed sample of CRs that had been issued since the last NRC Problem, Identification and Resolution (PI&R)inspection conducted in November 2005. The inspection team considered risk insights from the NRCs and unit-specific, stations risk analyses to focus the sample selection and plant tours on risk-significant systems and components.

The corrective action review was expanded to five years for evaluation of operational decision making, fire protection program corrective actions, and reactor level instrumentation.

The inspection team selected items from various processes used at NMPNS to verify that they were appropriately considered for entry into the CAP. Specifically, the inspection team reviewed a sample of operability determinations, action requests, operational significant issues list, trend reports, engineering system health reports, and completed surveillance tests. The inspection team also reviewed work orders for selected components to determine if station personnel entered issues identified during the performance of preventive maintenance into the CAP.

The inspection team reviewed CRs to assess whether Constellation adequately evaluated and prioritized identified problems. The issues reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. Samples of CRs that were assigned lower levels of significance were also reviewed by the inspection team to ensure they were appropriately classified. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. For significant conditions adverse to quality, the inspection team reviewed Constellations corrective actions to preclude recurrence. The inspection team observed daily condition report screening meetings, in which station personnel reviewed new CRs for prioritization and assignment, and corrective action review board meetings, which reviewed corrective actions for Category I and II CRs. The inspection team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems.

The inspection team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The inspection team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective. The inspection team also reviewed station timeliness in implementing corrective actions and their effectiveness in precluding recurrence for significant conditions adverse to quality.

The inspection team reviewed corrective actions associated with selected non-cited violations (NCVs) and findings to determine whether the station properly evaluated and resolved these issues.

(2) Assessment Identification of Issues No findings of significance were identified in the area of identification of issues.

The condition reporting process facilitated the initiation, tracking, and trending of CRs. Approximately 6,000 CRs were written each year. There was a low threshold for the identification of issues and, in most cases, problems identified during plant activities were entered into the CAP when appropriate. In general, the inspection team considered the identification of problems at NMPNS to be appropriate. Exceptions were noted however, in the area of housekeeping and valve labeling at Unit 1. During plant tours, the inspection team noted ladders, staging and security delay fences were not placed in designated storage areas, or removed when no longer required. Also valve labeling at Unit 1 was not consistent in that certain valves were identified with metal tags that only contained the valve number, while other valve labels contained tags that included the numeric identifier as well as a descriptive name. The inspection team noted that although the housekeeping at Unit 1 did not meet Constellation Energy standards, and valve labeling was not consistent, these conditions were of minor significance because they did not affect the operability of safety-related equipment or result in improper valve manipulations. These observations were captured in the CAP as CRs 2007-4016, 4018, 4024 and 4027.

The inspection team noted that relatively few deficiencies were identified by external organizations (including the NRC) that had not been previously identified by NMPNS personnel. Issues that had not been identified by NMPNS, such as the failure of departments to assume certain activities performed by the chemistry department to facilitate a workforce reduction were being addressed.

Prioritization and Evaluation of Issues No findings of significance were identified in the area of prioritization and evaluation of issues.

The inspection team determined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the problem. CRs were screened for operability and reportability, categorized by significance (1 through 4), and assigned to a department for evaluation and resolution. The various condition report screening and management review groups appropriately considered human performance issues, radiological safety concerns, repetitiveness, and adverse trends in their reviews. Although items generally were appropriately screened, the inspection team did identify the following weaknesses with respect to properly prioritizing and evaluating CRs, as well as establishing work priority:

• Constellation has experienced an increased oscillation on the GEMAC 12 level instrument in the control room since the end of refueling outage (RFO) 19 in April 2007. The GEMAC 12 level instrument is one input to the reactor vessel level control system. Although this oscillation has routinely caused an increased level difference between the GEMAC 11 and 12 level instruments, Constellation did not issue a CR that specifically evaluated the potential adverse effects this oscillation may have had on high-pressure coolant injection (HPCI) level control. Constellation conducted engineering evaluations and surveillance test data demonstrated the oscillations did not have an adverse effect on HPCI level control. Therefore the issue was minor. The lack of an evaluation was documented in CRs 2007-3956 and 4029.

• Several area coolers in the non safety-related ventilation systems in Unit 1 have service water leaks that have existed for several months. Although the leakage had been collected and directed to floor drains, the inspection team noted that some of the defective coolers are in close proximity to safety-related electrical switchboard panels, which could be adversely affected if the temporary collection facilities failed. Further, the service water leakage from these coolers has to be processed by the Unit 1 waste collection systems. These concerns were not fully considered when establishing the work priority for repairing these degraded components.

The prioritization of work for the room coolers was documented in CR 2007-4026.

Effectiveness of Corrective Action No findings of significance were identified in the area of effectiveness of corrective action.

The inspection team concluded that with certain exceptions discussed below Constellation was effective in the resolution of problems and implementation of corrective actions. The problems identified using a root or apparent cause methodologies were resolved in accordance with program and NRC requirements. The inspection team concluded that corrective actions were generally completed in an appropriate time frame. However, the inspection team identified three instances where corrective actions were incomplete.

• At Unit 1, Constellation had experienced a repeat event associated with unexpected reactor level increases while in long-path recirculation when the plant is shutdown. Although a CR was issued to appropriately document these repeat events, the CR was closed without identifying or completing corrective actions. When this was identified by the inspection team, Constellation concluded that this was contrary to station expectations and issued CR 2007-3956 to address the issue.

• Constellation has been ineffective in tracking and implementing actions to ensure air-operated valve (AOV) design basis updates are completed in a timely fashion to minimize potential vulnerabilities associated with risk significant AOVs. Constellation has an updated action plan to complete AOV design basis updates by the end of this year and no current AOV operability issue was identified. This issue was documented in CR 2007-4028

• Feedwater level control valves FCV-29-137 and FCV-29-141 at Unit 1 have seat leakage that exceeds vendor specifications. As a result, following a reactor plant trip, reactor vessel water level typically exceeds the desired levels described in the Unit 1 Final Safety Analysis Report, which requires operators to take manual actions following a reactor scram to ensure reactor vessel water level remains within allowable levels. Although the leakage has been a longstanding degraded condition, and contributed to a reactor vessel overfill event that occurred in November 1996, Constellation has not implemented effective actions to address this condition. This issue was documented in CR 2007-4015. The team concluded that this issue was minor because the feedwater system met its design basis and operator procedures and training ensured manual actions were completed.

b.

Assessment of the Use of Operating Experience

(1) Inspection Scope The inspection team reviewed how the NMPNS reviewed and assessed NRC generic communications that discussed potential design vulnerabilities associated with internal flooding and tornado loading for applicability to Unit 1. The inspection team also observed routine plant activities to determine if industry operating experience was considered during the performance of routine and infrequently performed activities.

(2) Assessment Industry operating experience was routinely considered during the performance of routine plant activities. For example, during shift briefing activities, relevant industry operating experienced was reviewed and discussed before the commencement of shift activities. Additionally, operating experience was reviewed during the daily meeting of plant staff and considered for applicability to the site.

Although industry operating experience was routinely considered during the performance of routine plant activities, the inspection team noted that certain NRC generic communications that discussed design vulnerabilities regarding internal flooding and tornado wind loads were not fully assessed for applicability to Unit 1.

For example, although NRC Information Notice 83-44, Potential Damage to Redundant Safety Equipment as a Result of Backflow Through the Equipment and Floor Drain System identified that check valves in floor drain systems may not function, the operability of the floor drain system check valves were not tested or verified at Unit 1. Similarly although Regulatory Issue Summary 2006-23.

Post-Tornado Operability of Ventilating and Air-conditioning Systems Housed in Emergency Diesel Generator Rooms, identified that diesel generator ventilation systems may be vulnerable to tornado missile hazards, this concern also was not fully assessed for applicability to the Unit 1 diesel generator intake louvers.

The team noted that there was no evidence that the non return check valves in the floor drain sumps were degraded. Further, the diesel generator ventilation system at Unit 1 was not originally licensed to withstand tornado generated missile hazards.

These observations were documented in CRs 2007-4019 and 2007-4021.

c.

Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspection team reviewed a sample of Quality and Performance Assessment audits, departmental self-assessments, and assessments conducted by independent organizations. A specific list of documents reviewed is included in the Attachment to this report. These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and self-assessments was evaluated by comparing audit and self-assessment results against self-revealing and NRC-identified findings, as well as observations during the inspection.

(2) Assessment No findings of significance were identified in the area of audits and self-assessments. The inspection team observed that, overall, audits and assessments were critical and, in most cases, appropriate actions were taken to address identified issues.

d.

Assessment of Safety Conscious Work Environment

(1) Inspection Scope The inspection team assessed the SCWE at NMPNS through discussions with plant personnel, observations of plant meetings and activities and review of documents.

Specifically, the inspection team assessed whether people were hesitant to raise safety concerns to their management and/or the NRC. As part of this review, the inspection team reviewed results from a Constellation and NMPNS safety culture survey, and discussed the results with the site program manager. The inspection team also reviewed Constellation's Employee Concerns Program to determine if employees were aware of the program and had used it to raise concerns. The inspectors observed and discussed the use of the corrective action system by NMPNS personnel.

(2) Assessment No findings of significance were identified.

Based on interviews, observations of plant activities, and reviews of the CAP and Employee Concern Program, the inspectors determined that site personnel were willing to raise safety issues and document them in the CAP. The inspection team did not identify evidence of conditions to the contrary relating to nuclear safety issues. The inspection team assessed that NMPNS's investigation of, and corrective action for, a CR which indicated that some personnel may not feel free to initiate CRs when warranted, was thorough. The inspection team noted that CRs had been written by a variety of personnel, from workers to managers.

4OA6 Meetings, including Exit

On June 28, 2007, the inspection team presented the inspection results to Mr. Keith Polson and other members of the NMPNS staff. No proprietary information was reviewed during the conduct of this inspection.

ATTACHMENT: Supplemental Information In addition to the documentation that the inspectors reviewed (listed in the

), copies of information requests given to NMPNS personnel are in ADAMS under accession number ML07208004.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Polson, Site Vice President

K. Nietmann, Acting Site Vice President

N. Conicella, Manager, Operations

R. Dean, Director, Quality and Performance Assessment

L. Dick, Principle Quality Performance and Assurance Supervisor

M. Faivus, General Supervisor, Chemistry

T. Forenza, Design Engineering Supervisor

J. Kaminski, Director Emergency Preparedness

J. Laughlin, Manager, Engineering Services

T. Maund, Manager, Maintenance

P. Mazzaferro, Assistant Engineering Manager

J. McCrobie, Director, Performance Improvement

W. Paulhardt, Manager, Integrated Work Management

M. Schimmel, Plant General Manager

T. Syrell, Director, Licensing

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None