IR 05000255/2004004

IR 05000255-04-004, on 02/23/2004 - 03/05/2004, Palisades Nuclear Power Plant, Baseline Inspection of the Identification and Resolution of Problems

ML040910453
Person / Time
Site:	Palisades
Issue date:	04/01/2004
From:	Eric Duncan Division Reactor Projects III
To:	Domonique Malone Nuclear Management Co
References
IR-04-004
Download: ML040910453 (35)

Text

April 1, 2004

SUBJECT:

PALISADES NUCLEAR GENERATING PLANT NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000255/2004004

Dear Mr. Malone:

On March 5, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Palisades Nuclear Generating Plant. The enclosed report documents the inspection findings which were discussed on March 5, 2004, with you and members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved a selected examination of procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. In general, the issues reviewed during the inspection were properly categorized and evaluated, although some evaluations were narrowly focused and of limited effectiveness. Overall, the corrective actions reviewed during the inspection were appropriately implemented; however, some examples were identified where corrective actions were not fully implemented or fully effective in correcting the identified problems.

During this inspection, the inspectors found examples of corrective action program implementation weaknesses that were similar to those identified during the previous Problem Identification and Resolution inspection. However, the examples were limited in number and significance relative to our previous inspection. The inspectors noted that improvements have been demonstrated in the implementation of your corrective action program over the past year.

It was also apparent during the review of internal assessments that your staff is focused on improving the corrective action program. Several positive observations during this inspection appear to be the result of your efforts to improve the implementation of your corrective action program in response to previously identified concerns. 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 Publicly Available Records (PARS) component of 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/

Eric R. Duncan, Chief Branch 6 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2004004 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-255 License No:

DPR-20 Report No:

050000255/2004004 Licensee:

Nuclear Management Company, LLC Facility:

Palisades Nuclear Generating Plant Location:

27780 Blue Star Memorial Highway Covert, MI 49043-9530 Dates:

February 23 through March 5, 2004 Inspectors:

B. Kemker, Senior Resident Inspector, D. C. Cook A. Dunlop, Senior Reactor Engineer, RIII M. Garza, Resident Inspector, Palisades R. Ng, Reactor Engineer, RIII Approved by:

Eric R. Duncan, Chief Branch 6 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000255/2004004; 02/23/2004 - 03/05/2004; Palisades Nuclear Generating Plant;

Baseline Inspection of the Identification and Resolution of Problems.

The inspection was conducted by resident and region-based inspectors. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

Identification and Resolution of Problems The inspectors concluded that the licensees corrective action program attributes enabled timely problem identification commensurate with the significance level and that the threshold for problem identification was sufficiently low. Nuclear Oversight assessment reports appropriately identified problems, including issues associated with corrective action implementation. The majority of issues reviewed during the inspection were properly categorized and evaluated, although some evaluations were narrowly focused and of limited effectiveness.

Overall, the corrective actions reviewed during the inspection were appropriately implemented; however, some examples were identified where corrective actions were not fully implemented or fully effective in correcting the identified problems. During this inspection, the inspectors found similar examples of corrective action program implementation weaknesses to those identified during the previous Problem Identification and Resolution Inspection. However, the examples were limited in number and significance relative to this previous inspection. The inspectors noted that improvements have been demonstrated in the licensees corrective action program over the past year. It was also apparent during the review of internal assessments that the licensee was properly focused on improving the corrective action program.

REPORT DETAILS

4OA2 Problem Identification and Resolution

.1 Effectiveness of Problem Identification

a. Inspection Scope

The inspectors reviewed NRC inspection report findings issued over the last 14 months, selected corrective action documents, Nuclear Oversight assessments, other self assessments, operating experience reports, and trend assessments to determine if problems were being entered into the licensees corrective action program at the proper threshold. The inspectors also conducted focused plant walkdowns of the component cooling water, service water, and radiation monitoring systems to ensure that equipment problems were entered into the corrective action program.

b.

Assessment In general, the licensees staff identified issues and entered them into the corrective action program at an appropriate level. The licensee appropriately used the corrective action program to document instances where previous corrective actions were ineffective or inappropriate.

b.1 Identification Threshold The licensee defined the threshold for issues to be entered into the corrective action program in Palisades Nuclear Plant Administrative Procedure No. 3.03, "Corrective Action Process." In addition, Nuclear Management Company fleet procedure FP-PA-ARP-01, "Action Request Process," was recently adopted for use at Palisades.

The current electronic database system, called TeamTrack, was implemented in August 2002. A corrective action document in TeamTrack was called an Action Request or CAP. Prior to TeamTrack, corrective action documents were called condition reports or CPALs. The generation rate for condition reports increased over the past year with 4820 CAPs generated in 2002 and 6554 CAPs generated in 2003.

The licensee stated one reason for the increase was more involvement of several organizations after training was provided in the use of the TeamTrack process. The generation rate and significance level distribution of these condition reports appeared appropriate.

b.2 Operating Experience The inspectors determined that the licensee adequately identified, evaluated, and developed corrective actions for industry operating experience that could potentially impact the plant. However, one example was identified where an evaluation did not address the extent of condition aspect of the issue. Condition report CAP 005116 was associated with the preconditioning of main steam isolation valves (MSIVs) prior to inservice testing. Licensee personnel determined that this issue was applicable to Palisades and subsequently revised MSIV testing and maintenance practices to address the preconditioning issue. However, no extent of condition review was performed.

b.3 Nuclear Oversight Assessments The inspectors reviewed Nuclear Oversight assessment reports and determined that the Nuclear Oversight staff, in general, effectively identified plant performance issues. In particular, the inspectors did not identify significant performance issues during the inspection that were not described in previous Nuclear Oversight assessment reports.

b.4 Trending Based on a weakness with trending noted during the previous Problem Identification and Resolution (PI&R) inspection, the inspectors reviewed a number of trending condition reports. In general, the licensees effort to determine whether trends existed has improved since the last PI&R inspection. However, in two condition report evaluations reviewed by the inspectors, the licensee identified that the coding of a number of condition reports was not properly completed to perform adequate trending. This had a potentially adversely impact on the ability to accurately trend issues within the corrective action program. One of the two condition report evaluations, an apparent cause evaluation, is discussed in Section 4OA2.2.b.2.1 of this report. The other condition evaluation is discussed below.

Condition Evaluation 003399 was written to evaluate a trend identified by Nuclear Oversight. This condition evaluation identified that skill-based errors were the most prevalent human error classification during 2002. The trend evaluation, however, determined that the data used to identify the trend was limited due to the incomplete coding on the condition reports. As a result of this evaluation, a corrective action was implemented that re-coded the previous 3 months of condition reports. The data was then re-evaluated. The results did not indicate an adverse skill-based error trend.

.2 Prioritization and Evaluation of Issues

a. Inspection Scope

The inspectors independently assessed the prioritization and evaluation of a sample of corrective action program documents. The inspectors reviewed previous inspection reports and corrective action program documents to verify that identified issues were appropriately characterized and prioritized. The assessment included a review of the category assigned, operability and reportability determinations, apparent cause and root cause evaluations, extent of condition evaluations, and the adequacy of the assigned corrective actions. The inspectors also attended several Condition Review Group meetings, during which condition reports were screened and assigned a significance level. The inspectors also attended Corrective Action Review Board meetings, which reviewed completed root cause evaluations and granted extensions for the completion of corrective actions.

b.

Assessment The inspectors verified that the issues reviewed were properly categorized and evaluated.

b.1 Overview of Prioritization and Evaluation Process The corrective action process included a review of new condition reports by the Condition Review Group, whose membership included senior plant management. The Condition Review Group assigned a significance level to each condition report, with "A" being a significant condition adverse to quality requiring a root cause evaluation, "B" being a condition adverse to quality requiring an apparent cause evaluation, and "C" being a condition adverse to quality requiring a condition evaluation to determine appropriate corrective actions. A significance level "D" was also assigned for conditions that were not adverse to quality.

The backlog of open condition reports was about 1830 at the time of the inspection.

This backlog included condition reports that required evaluation and condition reports for which the evaluations were completed, but the corrective actions had not been implemented. The inspectors noted that the backlog was relatively unchanged or had slightly increased since the last PI&R Inspection in November 2002. This number of open condition reports did not meet the licensees goal of less than 1550 for the backlog, but appeared to be understood and was receiving appropriate management attention.

b.2 Apparent Cause Evaluations The inspectors reviewed a sample of 27 apparent cause evaluations during the inspection. In general, the evaluations appropriately evaluated the problems and reasonable corrective actions were identified to address the conditions. However, the inspectors identified that some of the apparent cause evaluations reviewed were either narrow in scope or lacked quality.

The inspectors also found several examples where substantive comments provided by the reviewers on the Apparent Cause Evaluation Score Sheets to improve the quality of the evaluations were not consistently addressed. The inspectors noted that the licensees program did not require score sheet comment resolution unless there was a failing grade on the score sheet. The inspectors considered this to be a missed opportunity to improve the quality of apparent cause evaluations and associated corrective actions.

Some specific observations with the apparent cause evaluations are described below.

b.2.1 Apparent Cause Evaluation 003221 The following apparent cause evaluation was narrow in scope and impacted the licensees ability to perform an extent of condition review.

Apparent Cause Evaluation 003221 was written to evaluate a potential adverse trend with inappropriate mechanical maintenance department personnel radiation work practices based on three events that occurred in November and December 2003. The apparent cause evaluator searched the TeamTrack database for contamination control and dose control related incidents in 2003. The evaluation concluded that there was no adverse trend with contamination control or dose control within the mechanical maintenance department.

The inspectors reviewed the apparent cause evaluation and identified the following weaknesses:

The inspectors noted that the scope of the evaluation was narrowed by the evaluator so that if an adverse trend existed, it would not have been identified.

Because responsible department codes were not utilized for many of the condition reports, they were excluded from review during the evaluation. Only 16 of 67 contamination control incidents were coded with a responsible department and only 30 of 79 dose control incidents were coded with a responsible department code. Of those, only 3 of 16 contamination control incidents and 4 of 30 dose control incidents were coded for the mechanical maintenance department and were included in the review.

The inspectors noted that a significant comment provided by the reviewer on the Apparent Cause Evaluation Score Sheet was not addressed. The reviewer disputed the results of the evaluation, stating that a short-term adverse trend existed based on three events within a 2-week period. However, because the evaluation score sheet had a passing score, no follow up action was initiated.

The inspectors noted that because the evaluation scope was narrowed, an extent of condition review was not accomplished.

b.2.2 Apparent Cause Evaluation 002847 The following apparent cause evaluation was narrow in scope and impacted the licensees ability to perform an extent of condition review.

Apparent Cause Evaluation 002847 was written to evaluate problems identified during the calibration of loop 1B pressurizer spray valve positioner POC-1057. Multiple entries were made into the containment building during a forced outage in December 2002 due to incorrect parts and positioner installation problems. The total dose received by the workers exceeded 1800 millirem, which surpassed the dose estimate by a factor of three. The evaluation concluded that the replacement positioner was not correct.

The inspectors reviewed the apparent cause evaluation and identified the following weaknesses:

The inspectors noted that the scope of the evaluation was narrow and focused only on this particular valve positioner and an identical positioner for the loop 2A pressurizer spray valve. As a result, the corrective actions identified in the evaluation were limited to the replacement of these two positioners and the procurement of correct replacement parts for these valve positioners and other valve positioners in the plant of the same make and model.

The inspectors noted that because the evaluation scope was narrow, the extent of condition review only considered valve positioners in the plant of the same make and model.

The inspectors noted that the limited scope of the cause evaluation and extent of condition review was a missed opportunity to prevent or reduce the number of maintenance work execution problems in general, and specifically those with potential dose consequences.

The inspectors noted that corrective action CA 018452 was initiated to evaluate possible solutions to reduce the dose accumulated for occasions where maintenance on valve positioners is performed in high radiation areas. The purchase of equipment to support mockup training was reviewed by the licensee; however, the corrective action was closed without purchasing the materials and no other action was taken. Licensee personnel stated that they planned to purchase the mockup materials, but this was not tracked in the corrective action program.

b.2.3 Apparent Cause Evaluation 002857 The following apparent cause evaluation was closed to another tracking system. The inspectors identified this practice as a potential corrective action implementation vulnerability.

Apparent Cause Evaluation 002857 was written to evaluate repetitive problems with main turbine control valve mis-operation due to degraded wiring. The evaluation concluded that factors including vibration and disassembly during turbine maintenance resulted in wear to the wiring insulation.

The inspectors noted that the only corrective action for this issue was to upgrade the wiring to the reheat stop and intercept valves, which included the identification of termination points to support turbine maintenance activities. The licensee concluded that to implement this corrective action a project study included in a long-term contract with the turbine vendor was necessary. As a result, licensee personnel closed the corrective action without implementing any plant change to correct the problem. The inspectors noted that the system engineer was tracking the wiring upgrade plan in the System Health and Status Report.

b.2.4 Apparent Cause Evaluation 003152 The following apparent cause evaluation lacked technical rigor and did not identify the root cause of the issue. However, no adverse consequences occurred.

Apparent Cause Evaluation 003152 was written to evaluate a potential adverse trend identified with component cooling water system performance. The evaluation concluded that decreasing system resistence, which would lead to decreasing pump head, was the cause for slowly decreasing system discharge pressure.

The inspectors identified that the apparent cause of the potential component cooling water pump degradation proposed in the evaluation was not reasonably justified. The cause was determined to be decreasing system resistence, which would lead to decreasing pump head. However, the pump data for all three component cooling water pumps were not all decreasing or decreasing at the same rate. Therefore, it was not reasonable to conclude that the cause could be attributed to a system problem since all three pumps were tested within the same system and one would expect similar results for each pump. The inspectors agreed with the licensees conclusion that the pumps were able to perform their design function.

b.2.5 Apparent Cause Evaluation 003098 The following apparent cause evaluation was determined to involve weaknesses with the resolution of comments by licensee reviewers.

Apparent Cause Evaluation 003098 was written to evaluate repetitive radiological effluent monitoring system sample pump failures.

The apparent cause evaluation was reviewed and received a very low quality score.

The reviewer provided numerous comments on the Apparent Cause Evaluation Score Sheet, however the evaluation was not revised. These comments included:

A corrective action for an identified contributor for the pump failures was removed from the evaluation because the evaluator did not believe a procedure change request could be used as a corrective action.

There was no safety significance evaluation as required by the Apparent Cause Handbook.

There was no internal operating experience search conducted for this evaluation as required by the Apparent Cause Handbook.

The extent of condition review did not address all the equipment that may have been affected by the problem.

b.2.6 Apparent Cause Evaluation 002736 The following apparent cause evaluation was determined to involve weaknesses with the resolution of comments by licensee reviewers.

Apparent Cause Evaluation 002736 was written to evaluate the failure of feedwater purity air compressor C-903B.

The inspectors noted that the Apparent Cause Evaluation Score Sheet included a comment that the cause was not identified and compensatory or interim corrective actions were not addressed. In this case, troubleshooting was not completed on the compressor failure prior to closing the evaluation, but the actual cause was determined at a later date during the troubleshooting activities. There were no apparent actions taken to address the comments on the score sheet.

b.2.7 Apparent Cause Evaluation 002601 The following apparent cause evaluation did not fully address a potential extent of condition vulnerability.

Apparent Cause Evaluation 002601 was written to evaluate two issues with design calculations for the Air-Operated Valve Program.

The inspectors noted that the evaluation did not discuss or address both issues identified in the condition report description. First, the design basis calculations did not include margin for degradation of the valve and/or actuator. This issue was adequately addressed in the evaluation and a 5 percent margin was added to the design calculations. The second issue concerned a dimensional error on the piston area used in calculating the available thrust to close several valves. Although the associated calculations were revised using the correct piston diameter for the valves with the same actuator, the evaluation did not determine the cause for using incorrect values.

Determining the cause for the incorrect dimension value (e.g. incorrect vendor information) may have expanded the extent of condition to other valves with different actuators whose calculations relied on similar information.

b.3 Root Cause Evaluations The inspectors reviewed a sample of 14 root cause evaluations during the inspection.

In general, the evaluations appropriately evaluated the problems and reasonable corrective actions were identified to address the issues. However, the inspectors identified that two of the root cause evaluations reviewed were either narrow in scope or lacked quality. Specific observations are discussed below.

b.3.1 Root Cause Evaluation 000330 Root Cause Evaluation 000330 was written to evaluate inappropriate radiation worker practices identified during the Spring 2003 refueling outage that resulted in violations of the requirements for the control and posting of high radiation areas. Two radiation workers entered a posted high radiation area without knowledge of area dose rates and removed radioactive material from the area. The workers relocated the materials to another area, creating an unposted high radiation area. The evaluation concluded that the workers used poor judgement and failed to follow plant procedures.

The inspectors reviewed the subject root cause evaluation and identified the following weaknesses:

The inspectors identified that two corrective actions to prevent recurrence were inadequate. The first action was limited to counseling the individuals involved in the incident and would not prevent other workers from making similar mistakes.

The second action prescribed an effectiveness review through tracking the number of incidents of unposted high radiation areas through the upcoming Fall 2004 refueling outage to determine if more in-depth training of workers on radiation protection standards would be necessary. The inspectors determined that this action would not prevent other workers from making similar mistakes until the next refueling outage was completed.

The inspectors identified that a corrective action to establish the duties and standards for the selection of the Containment Area Coordinator position (CA 019960) was closed, but not completed. Although Plant Procedure 2.09, "Outage Planning, Scheduling and Management", Attachment 17, "Outage Organization Responsibilities," was revised to address a specific performance problem identified with the Containment Area Coordinator performing physical work, no standards for the selection of individuals assigned to the Containment Area Coordinator position were established. The need for appropriate standards was highlighted in the root cause evaluation because the Containment Area Coordinator involved in this incident had not performed work in the containment building since at least 1990.

The inspectors noted that a corrective action to perform a training needs analysis for the duties of the Containment Area Coordinator position was completed which concluded that no additional training was needed. This conclusion was reached because only a limited change to the plant procedure delineating the Containment Area Coordinators roles was implemented. The inspectors concluded that this was a missed opportunity to improve on the knowledge and qualifications of individuals selected to be Containment Area Coordinators since no new standards were provided to the plants Training Department to evaluate as part of its training needs analysis.

The inspectors noted that the root cause evaluation identified that both workers received dose rate alarms on their electronic dosimeters. Although individual condition reports were written for each worker, the root cause evaluation did not evaluate the cause for the alarms and identify appropriate corrective actions.

This was noteworthy because one of the workers stated that he did not hear the alarm due to high background noise. The other worker stated that he heard the alarm but did not know that he was required to immediately leave the area and contact a radiation protection technician. The inspectors noted that the cause evaluations for the two individual condition reports were closed, and stated that the evaluations would be part of this root cause evaluation.

b.3.2 Root Cause Evaluation 000321 Root Cause Evaluation 000321 was written to evaluate an adverse trend identified with scaffolding installed in the plant that did not meet licensee installation standards. This root cause evaluation was intended to address problems associated with two separate condition reports. The first condition report, CAP 033667, "Seismic Scaffold Does Not Meet Installed Plant Equipment Separation Requirement," specifically described problems identified with the seismic qualification of plant scaffolding. The second condition report, CAP 033677, "Adverse Trend in Scaffold-Related Issues," was written to address 15 condition reports describing scaffolding issues between November 2002 and February 2003. This condition report was subsequently closed referencing the first condition report.

The inspectors identified that while the root cause evaluation adequately addressed the seismic qualification aspects of the scaffolding issue described in the first condition report, it did not address the potential adverse trend aspects of other scaffolding problems identified in the second condition report. The evaluation concluded that the procedure for erecting scaffolding did not effectively represent the margin required to maintain a one inch separation criterion. Because the scope of the evaluation was narrow, the corrective actions that followed were limited to only addressing the seismic qualification of scaffolding.

.3 Effectiveness of Corrective Action

a. Inspection Scope

The inspectors reviewed corrective action documents and recent plant issues to determine if corrective actions were implemented in a timely, appropriate, and effective manner. The inspectors conducted a walkdown of the component cooling water, radiation monitoring and service water systems to assess the material condition of these systems and to verify that the licensee appropriately identified degraded conditions within the corrective action program. The inspectors reviewed historical fuel reliability issues to assess whether the licensee had identified and implemented appropriate corrective actions. Additionally, the inspectors evaluated the current status of corrective actions to improve a previously identified substantive cross-cutting issue in the area of PI&R.

b.

Assessment In general, the licensees corrective actions for the samples of condition reports the inspectors reviewed were appropriate and appeared to have been effective. The inspectors noted that the licensee generated condition reports when a corrective action that was either inadequate or inappropriate was identified. The inspectors identified a vulnerability with examples of closing corrective actions to other tracking methods outside of the licensees corrective action process, which could lead to incomplete actions.

b.1 Observations on the Effectiveness of Corrective Actions The inspectors identified one case in where corrective actions were not fully effective in correcting the identified issue to prevent recurrence.

Level "A" condition report CAP 035210 was written in response to inappropriate radiation worker practices identified during the Spring 2003 refueling outage that resulted in violations of the requirements for the control and posting of high radiation areas. This issue was discussed in Section 4OA2.2.b.3.1 of this report. During a review of the root cause evaluation associated with CAP 035210, the inspectors identified that two corrective actions to prevent recurrence were inadequate since they would not prevent other workers from making similar mistakes. The inspectors also identified that there was a corrective action to establish the duties and standards for the selection of the Containment Area Coordinator that was closed, but not completed.

b.2 Practice of Closing Condition Reports to Other Tracking Documents The inspectors identified the following examples where corrective actions were closed to another tracking mechanism other than the corrective action program. This represented a potential vulnerability in the ability to implement effective corrective actions in a timely manner.

CAP 032351 was written in response to problems identified during the calibration of the loop 1B pressurizer spray valve positioner during which the total dose received by workers exceeded the original dose estimate for the job by a factor of three. As discussed in Section 4OA2.2.b.2.2 of this report, the inspectors identified that a corrective action to reduce dose in high radiation areas was closed although licensee personnel stated that they planned on implementing the action.

CAP 032426 was written in response to repetitive problems with main turbine control valve mis-operation due to degraded wiring. As discussed in Section 4OA2.2.b.2.3 of this report, the inspectors identified that the corrective action was closed without implementing any plant change to correct the condition. The inspectors noted that the system engineer was tracking a wiring upgrade plan in the System Health and Status Report.

CAP 029158 was written to address a high energy line break barrier control issue. The inspectors noted that corrective action CA 015988 was initiated to add a new section to Design Basis Description 7.03, "Plant Protection Against High Energy Line Breaks." The corrective action was closed based on initiating Design Basis Description change request 1867, which was identified as an enhancement and was added to the licensees Design Basis Description tracking list for future implementation. Based on the licensees change process, enhancement changes would not be incorporated until after 10 changes were identified or the tracking list exceeded one page.

CAP 033244 was written regarding an Emergency Preparedness self-assessment that identified a need for an effective feedback process to stakeholders. The inspectors identified that a corrective action, CA 018943, to develop a monthly newsletter and an Emergency Preparedness website was closed and was being tracked by the Emergency Preparedness Steering Committee Action Item Tracking List.

CAP 031874 was written by Nuclear Oversight for several discrepant issues related to the raw water corrosion program. Nuclear Oversight identified two condition reports that contained corrective actions closed to procedure change travelers before the actual change was issued.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed members of the plant staff representing all major work groups at various levels of responsibility. The inspectors conducted the interviews to assess whether there were impediments to the establishment of a safety conscious work environment. The interviews included questions similar to those listed in Appendix 1 of NRC Inspection Procedure 71152, "Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues." The inspectors also reviewed the stations procedures related to the Employee Concerns Program (ECP),and discussed the implementation of this program and selected concerns with the licensees ECP Coordinator.

b.

Assessment Plant personnel interviewed did not express any concerns regarding a safety conscious work environment. They were generally aware of and familiar with the corrective action program and other plant processes, including the ECP, through which concerns could be raised. In general, the plant personnel interviewed considered the licensees corrective action program to be successful in identifying and correcting issues. They also indicated that individuals were encouraged by their management to identify problems.

Most plant personnel interviewed stated that they initiated condition reports regarding issues they identify. The inspectors noted one potential weakness in that the security officers and some maintenance personnel interviewed stated that they did not initiate condition reports regarding issues that they identify. However, they stated that they did refer those issues to their immediate supervisors for entry into the corrective action program.

Most plant personnel interviewed stated that the initiators of the condition reports received feedback on the resolution of their issues. However, several plant personnel indicated that they did not receive feedback on issues. In particular, the inspectors noted that several maintenance department personnel stated that they did not receive feedback. This represented a potential weakness in the communication of the resolution of issues that were entered into the corrective action program.

Based on the interviews, the ECP Coordinator was appropriately focused on ensuring that plant personnel were aware of the ECP; reviewing individual concerns; and integrating, where appropriate, the ECP and corrective action program to resolve workers concerns.

.5 Resolution of Issues Documented in NRC Inspection Reports and Issues Identified

During the Last PI&R Inspection

a. Inspection Scope

The inspectors reviewed selected corrective program documents related to issues previously discussed in NRC inspection reports, including the previous PI&R Inspection in November 2002.

b.

Assessment During the PI&R Inspection in November 2002, the inspectors identified several concerns with the implementation of the corrective action program, including the following:

The plant identified issues and entered them into the corrective action process at an appropriate low level, although some exceptions to this practice were identified.

The majority of issues reviewed were properly categorized and evaluated although some evaluations were narrowly focused, particularly for apparent cause evaluations and extent of condition reviews.

Most corrective actions reviewed were appropriately implemented; however, some examples, including one inspection finding, were identified regarding corrective actions that were not fully implemented or fully effective in correcting the identified problem.

Corrective action follow-through and effectiveness is one aspect of the corrective action process that could be strengthened to reduce repeat issues at the plant.

During this inspection, the inspectors found some similar examples to those identified previously. However, the examples were limited in number and were of only minor significance. It was also apparent during the inspectors review of internal assessments that the licensee was properly focused on the continuing improvement of the corrective action program.

The inspectors also reviewed NRC inspection reports issued since November 2002 to determine if an adverse performance trend in problem identification and resolution existed. No adverse trend was noted.

4OA4 Cross-Cutting Issues

a. Inspection Scope

The inspectors reviewed NRC inspection reports issued since November 2002 to determine if the adverse performance trend in problem identification and resolution that was first identified during the 2001 annual assessment period had improved. Problem identification and resolution remained an area of concern during the 2002 annual assessment period due to the continued identification of findings involving corrective action program performance issues. This substantive cross-cutting issue was recently closed at the end of the 2003 annual assessment period.

b.

Assessment The inspectors determined that corrective action program performance issues had decreased substantially over the past year and since the last PI&R Inspection was performed. Although there were several corrective action program related findings identified in the last quarterly inspection report of 2002, the number of findings for 2003 decreased significantly. There were only three corrective action related findings during 2003. The following findings associated with the identification and resolution of problems were documented since November 2002:

Initiating Events Cornerstone

A finding of low to moderate safety significance (White) was identified for the failure to take effective corrective actions to address a series of events involving digging and excavating between the protected area and the switchyard that caused a loss of offsite power and loss of shutdown cooling event.

A Non-Cited Violation was identified for the failure to rigorously evaluate industry operating experience information, which resulted in inadequate preventive maintenance activities being developed for the 345 kilovolt transmission lines that connect the plant and switchyard. This resulted in an automatic reactor trip due to the failure of a connector holding a static wire on one phase of the transmission lines.

Mitigating Systems Cornerstone

• A Non-Cited Violation was identified for the failure to adequately evaluate the root cause and implement effective corrective actions to prevent recurrence of a leak on the instrument line for safety injection tank T-82D. This resulted in the inoperability of important safety-related equipment.

A Non-Cited Violation was identified for the failure to implement adequate corrective actions to prevent recurring problems with the seismic qualification of scaffolding near safety-related systems.

Barrier Integrity Cornerstone

A Non-Cited Violation was identified for the failure to identify that significant motor bearing degradation had rendered a Containment Building air cooler fan inoperable. This was due to a lack of rigor in the technical evaluation to determine operability of the fan with degraded motor bearings and the subsequent return to service of the fan in an inoperable condition.

A Non-Cited Violation was identified for the failure to promptly identify and correct problems with the operation of a door that affected the operability of the Control Room ventilation envelope.

Emergency Preparedness Cornerstone

A Non-Cited Violation was identified for the failure to adequately critique two Drill and Exercise Performance Indicator opportunities that occurred during licensed operator training sessions.

The inspectors concluded that each of these issues was due to a common causal factor associated with the failure to promptly and effectively identify and resolve conditions adverse to quality. The licensee implemented improvement initiatives as part of their Excellence Plan to focus on improving the quality of evaluations and strengthening the Condition Review Group and Corrective Action Review Board. The inspectors recognized that improvements have been demonstrated in the licensees corrective action program over the past year.

4OA6 Management Meetings

Exit Meeting Summary

The inspectors presented the inspection results to Mr. D. J. Malone and other members of licensee management at the conclusion of the inspection on March 5, 2004. The licensee acknowledged the information presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

Proprietary information was examined during this inspection, but is not specifically discussed in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Anderson, Nuclear Oversight Supervisor

M. Carlson, Engineering Director

P. Harden, Site Director

G. Higgs, Maintenance Manager

L. Lahti, Regulatory Affairs Manager

D. Malone, Site Vice President

B. MacKenzie, Corrective Action Supervisor

G. Packard, Operations Manager

R. Remus, Plant Manager

C. Scott, Employee Concerns Program Manager

D. Williams, Chemistry and Radiation Safety Manager

Nuclear Regulatory Commission

E. Duncan, Chief, Reactor Projects Branch 6

J. Lennartz, Senior Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

LIST OF ACRONYMS USED ADAMS Agency-wide Document and Management System AR Action Request ACE Apparent Cause Evaluation ALARA As Low As Is Reasonably Achievable CA Corrective Action CAP Corrective Action Program CFR Code of Federal Regulations CE Condition Evaluation DRP Division of Reactor Projects ECP Employee Concerns Program IR Inspection Report NRC Nuclear Regulatory Commission OE Operating Experience PARS Publicly Available Records PI&R Problem Identification and Resolution RCE Root Cause Evaluation WO Work Order