IR 05000220/2011008

IR 05000220-11-008, 05000412-11-008; Nine Mile Point Nuclear Station - NRC Problem Identification and Resolution Inspection Report

ML113260049
Person / Time
Site:	Nine Mile Point
Issue date:	11/22/2011
From:	Glenn Dentel Reactor Projects Branch 1
To:	Langdon K Constellation Energy Nuclear Group
Dentel G
References
IR-11-008
Download: ML113260049 (18)

Text

UNITED STATES N UCLEAR REGU LATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT O5OOO22O/2011008 AND 05000410/201 1008

Dear Mr. Langdon:

On October 21,2011, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station Units 1 and 2. The enclosed report documents the inspection results discussed with Mr. George Gellrich 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 Commission's 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 concluded that Constellation was generally effective in identifying, evaluating, and resolving problems. Nine Mile Point personnel identified problems and entered them into the corrective action program at a low threshold.

Nine Mile Point personnel prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

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

ln accordance with 10 CFR 2.390 of the NRC's "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 NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.oov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely, rue-1r Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-220, 50-410 License Nos.: DPR-63, NPF-69 Enclosure: I nspection Report 05000220 120 1 1 008 and 05000 41 0l 201 1 008 MAttachment: Supplementary Information cc Mencl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500022012011008, 0500041012011008; 1010312011 - 101211201 1; Nine Mile Point Nuclear

Station, Units 1 and2; Biennial Baseline Inspection of Problem ldentification and Resolution.

This NRC team inspection was performed by four regional inspectors and one resident inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Problem ldentification and Resolution The inspectors concluded that Constellation was generally effective in identifying, evaluating, and resolving problems. Constellation 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, Constellation 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 Constellation typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that, in general, Constellation adequately identified, reviewed, and applied relevant industry operating experience to Nine Mile Point operations. In addition, based on those items selected for review, the inspectors determined that Constellation's 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 site's safety conscious work environment.

No findings were identified.

REPORT DETAILS

4OA2 Problem ldentification and Resolution (711528)

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Proqram Effectiveness

a.

lnspection Scope The inspectors reviewed the procedures that described Constellation's corrective action program at Nine Mile Point Nuclear Station (NMPNS). 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 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Constellation procedure CNG-CA-1.01-1000, "Corrective Action Program." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed condition reports (CRs) selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day meetings, screening meetings, 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 ldentification ln addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventive maintenance work orders, completed surveillance test procedures, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generator (EDG) and liquid poison systems. Additionally, the inspectors reviewed a sample of CRs 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 Constellation entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of lssues The inspectors reviewed the evaluation and prioritization of a sample of CRs issued since the last NRC biennial Problem ldentification and Resolution inspection completed in October 2009. The inspectors also reviewed CRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' reviews 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 Constellation's 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 CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Constellation's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected non-cited violations (NCVs) and findings to verify that Constellation personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Constellation actions related to Unit 1 liquid poison deficiencies and Unit 2 feedwater issues.

b.

Assessment

(1) Effectiveness of Problem ldentification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Constellation generally identified problems and entered them into the corrective action program at a low threshold. Constellation staff at NMPNS initiated approximately 23,000 CRs between October 2009 and September 2011. The inspectors observed supervisors at the Plan-of{he-Day meetings, screening meetings, and Management Review Committee meetings appropriately questioning and challenging CRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Constellation trended equipment and programmatic issues, and appropriately identified problems in CRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corective action program as appropriate. Additionally, the inspectors concluded that personnelwere identifying trends at low levels. Although issues and concerns were generally identified and entered into the corrective action program, the inspectors identified some instances not yet identified by Constellation including the Unit 2 EDG air start system valves inadequately locked, carts improperly stored in the power block, broken clips on the 103 EDG valve covers, and water on the floor in the 102 EDG switchgear room.

The inspectors independently evaluated these deficiencies for significance in accordance with Inspection Manual Chapter (lMC) 0612, Appendix B, "lssue Screening,"

and IMC 0612, Appendix E, "Examples of Minor lssues." None of the examples had a significant impact on plant operations or equipment operability. The inspectors considered these issues to be of minor significance, and, as a result, not subject to enforcement action in accordance with the NRC's Enforcement Policy.

(2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.

Constellation screened CRs for operability and reportability, categorized the CRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The CR 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 CRs reviewed, the inspectors noted that the guidance provided by Constellation 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 identified an unresolved item (URl) where NMPNS personnel were not effective in evaluating an issue and implementing effective corrective actions.

This URI is documented in Section 4OA2.1.c.

(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, Constellation identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. The inspectors did observe some weaknesses in Constellation's resolution of degraded conditions. Forexample:

.

A corrective action was not completed as detailed in the corrective action program for adding a step to a maintenance procedure for the Unit 2 EDGs regarding adding a normal temperature band for the jacket water system. The temperature band was for trending and did not affect alarms that the operators would receive for abnormal temperatures.

.

A corrective action was not completed for adding a step to an operations procedure for draining the reactor cavity regarding establishing the accuracy of the utilized level indications. Numerous other actions were taken to ensure the reactor cavity draining would be completed in a controlled manner with accurate, redundant indication.

o An issue regarding the reduced capacity of the floor drain system in Unit 1 was identified in March and August2011. However, corrective actions to address the issue were not aggressively pursued until October 2011.

o An adverse trend regarding poor plant lighting conditions (bulbs needing replacement) was identified in June 2011. However, long term corrective actions were not implemented until October 2011. Temporary lighting and flashlights were being relied upon until the permanent lighting was properly restored.

The inspectors independently evaluated these issues for significance in accordance with IMC 4612, Appendix B, "lssue Screening," and IMC 0612, Appendix E, "Examples of Minor lssues." None of the examples had a significant impact on plant operations or equipment operability. The inspectors consider these issues to be of minor significance, and, as a result, not subject to enforcement action in accordance with the NRC's Enforcement Policy.

Findinqs Non-Safetv Related Molded-Case Circuit Breaker Preventive Maintenance

Introduction:

The inspectors identified a URI associated with NMPNS's failure to meet the fleet standard for applying preventive maintenance (PM) templates for Critical, non-safety related (NSR) molded-case circuit breakers (MCCBS).

Description:

In 2006, NMPNS began to apply Electric Power Research lnstitute (EPRI)recommended PM templates to NSR MCCBS. During the application process, NMPNS classified NSR MCCBS as Critical, Significant, Economic, or Run-to-Failure, and determined the PM activities to be performed. NMPNS appropriately classified breakers and assigned PM tasks using the site procedures and industry guidance available at that time.

In 2007, two new procedures, CNG-AM-1.01-1018 "Preventive Maintenance Program,"

and CNG-AM-1.01-2000 "Scoping and ldentification of Critical Components," were issued. CNG-AM-1.01-2000 requires a component to be classified as Critical if a functional failure would result in one of the following undesirable plant consequences:

reactor scram/trip from any power level; loss of generation (shutdown, downpower/derate >2Qo/o, or delay a unit Mode Change in startup); unplanned technical specification entry that requires shutdown with an action constraint of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less; engineered safety feature (ESF) actuation, half-scram or half-ESF actuation that cannot be immediately reset; failure to control a criticalfunction (level, temperature, pressure) of any of the following: reactor, primary containment, secondary containment, or fuel pool, or loss of any Maintenance Rule High Risk function; degradation of primary or secondary containment; degradation of capability to achieve or maintain cold shutdown; or loss of Emergency Operating Procedure function. NMPNS reviewed components that had previously been classified as Critical to ensure that the classification and PM activities complied with the new procedures.

In 2009, fleet engineering standard CNG-FES-039 "Preventive Maintenance Template Development, Review, Analysis and Application," was issued. This standard states that "PM Template deviations for Critical components should be rarely applied and should only be reserved for severe/hardship situations," for non-conservative deviations. The inspectors identified several differences between the templates and actual PMs completed for NSR breakers, including scope and frequency of clean and inspect of Critical breakers, and thermography of breakers.

ln 2008, NMPNS missed an opportunity to re-evaluate if the "clean and inspect" PM task should be performed on NSR MCCBs based on operating experience. In 2008, NRC Information Notice (lN) 08-18 "Loss of a Safety-Related Motor Control Center Caused by a Bus Fault," identified high resistance stab connections as the primary cause of a fire.

The lN identified poor PM as one of the causes of the high resistance connection. Upon receiving lN08-18, NMPNS reviewed the PM templates for safety-related MCCBs, but not NSR MCCBS. In June 2011, NMPNS experienced a fire on a Significant NSR breaker, resulting in the declaration of an Unusual Event.

The differences between the PM templates and actual station practices is unresolved pending inspector determination if a performance deficiency exists and if this issue is more than minor. (URl 05000220,41012011008-01, lnconsistencies Between Non-Safety Related Breaker Preventive Maintenance Templates and Station Practices.

.2 Assessment of the Use of Operatinq Experience

a. Inspection Scope

The inspectors reviewed a sample of CRs associated with review of industry operating experience to determine whether Constellation appropriately evaluated the operating experience information for applicability to NMPNS 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 Constellation adequately considered the underlying problems associated with the issues for resolution via their corrective action program. ln 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 Constellation 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.

c. Findinqs 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 Constellation entered problems identified through these assessments into the corrective action program, when appropriate, and whether Constellation 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 self-assessments, audits, and other internal Constellation assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Constellation personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Constellation completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. ln general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findinos No findings were identified.

.4 Assessment of Safetv Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at NMPNS. 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 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 Constellation entered issues into the corrective action program when appropriate.

b. Assessment During interviews, NMPNS 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.

Findinqs No findings were identified.

40A6 Meetinqs. Includinq Exit On October 21,2011, the inspectors presented the inspection results to Mr. George Gellrich, Acting Site Vice President, and other members of the NMPNS 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

G. Gellrich, Acting Site Vice President

M. Flaherty, Acting Plant General Manager

L. Martiniano, Quality and Performance Assessment

M. Shanbhag, Licensing

P Swift, Engineering Manager

D. Wolniak, Performance lmprovement Unit Director

NRC Personnel

K. Kolaczyk, Senior Resident lnspector

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened

05000220,410t2011008-01 uRl Inconsistencies Between Non-Safety Related Breaker Preventive Maintenance Templates and Station Practices