IR 05000255/2010006
| ML100680555 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/09/2010 |
| From: | Jack Giessner Reactor Projects Region 3 Branch 4 |
| To: | Schwarz C Entergy Nuclear Operations |
| References | |
| IR-10-006 | |
| Download: ML100680555 (19) | |
Text
March 9, 2010
SUBJECT:
PALISADES NUCLEAR PLANT PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000255/2010006
Dear Mr. Schwarz:
On January 28, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed a biennial problem identification and resolution (PI&R) inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection results, which were discussed on January 28 with you and members of your staff.
The inspection examined 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 license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the PI&R. However, the team concluded that some NRC-identified findings from the inspection period were examples of issues the licensee should have recognized and addressed more aggressively.
In accordance with 10 CFR 2.390 of the NRC's "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 NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John B. Giessner, Chief Branch 4 Division of Reactor Projects
Docket No. 50-255 License No. DPR-20
Enclosure:
Inspection Report 05000255/2010006 w/Attachment: Supplemental Information
REGION III==
Docket No:
50-255 License No:
DPR-20 Report No:
05000255/2010006 Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Palisades Nuclear Plant Location:
Covert, MI Dates:
January 11 through January 28, 2010
Inspectors:
R. Lerch, Project Engineer, DRP
D. Jones, Reactor Inspector, DRS
T. Taylor, Operator Licensing Inspector, DRS
J. Cassidy, Senior Radiation Protection Inspector, DRS
P. Cardona, Reactor Engineer, DRP
Approved by:
John B. Giessner, Chief
Branch 4
Division of Reactor Projects
Enclosure TABLE OF CONTENTS
Summary of Findings.1 Report Details...............................................................................................................................2 4. OTHER ACTIVITIES.........................................................................................................2
4OA2 Problem Identification and Resolution (71152B).....................................................2 A. Assessment of the Corrective Action Program Effectiveness....................................2 B. Assessment of the Use of Operating Experience......................................................4 C. Assessment of Self-Assessments and Audits...........................................................5 D. Assessment of Safety Conscious Work Environment...............................................5
4OA6 Management Meetings...........................................................................................6 Exit Meeting Summary....................................................................................................6
SUPPLEMENTAL INFORMATION...............................................................................................1 KEY POINTS OF CONTACT.....................................................................................................1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED........................................................1 LIST OF DOCUMENTS REVIEWED.........................................................................................2 LIST OF ACRONYMS USED....................................................................................................7
Enclosure
SUMMARY OF FINDINGS
IR 05000255/2010006; 1/11/2010 - 1/28/2010; Palisades Nuclear Plant, Routine Biennial
Problem Identification and Resolution Inspection.
This inspection was performed by three NRC regional inspectors and the Palisades resident inspector. 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.
Problem Identification and Resolution On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Palisades was generally good. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria, were properly evaluated commensurate with their safety significance, and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. NRC findings, however, provided examples where the licensee needed to more aggressively recognize and address issues. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of review of the employee concerns program, safety culture survey results, and interviews conducted during the inspection, workers at the site are willing to enter safety concerns into the CAP.
No findings of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
The activities documented in Sections
.1 through.4 constituted one biennial sample of
problem identification and resolution (PI&R) as defined in IP 71152.
A.
Assessment of the Corrective Action Program Effectiveness
.1 Inspection Scope
The inspector reviewed the licensees corrective action program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.
The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC PI&R inspection in April 2008. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessment, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed condition reports (CRs) generated as a result of the facility personnels performance in daily plant activities. In addition, the inspectors reviewed CRs and a selection of completed investigations from the licensees various investigation methods, which included root cause, apparent cause, and common cause investigations.
The inspectors reviewed a risk-informed sample of licensee CAP documents, operating experience, audits, and self-assessments. A 5 year review was conducted of service water system health concerns and issues with vendor control. The inspectors also performed partial system walkdowns in the auxiliary building.
During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B, requirements.
Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including non-cited violations.
.2 Assessment
a.
Effectiveness of Problem Identification
- (1) The inspectors observed that, in general, issues were identified at an appropriate threshold. Condition reports were generated at a consistent rate from all plant organizational groups throughout the inspection period. In addition, discussions with the plant staff and the employee concerns program (ECP) manager indicated willingness by employees to raise issues through the CAP. The CAP staff also monitors program performance using monthly indicators. During the inspection, a notable exception to CR initiation was identified by the licensee staff of calibrated measuring and test equipment not having CRs generated for missing calibration checks. An apparent cause investigation was initiated for this issue.
- (2) Observations Recognition of Issues During an analysis of NRC findings over the inspection period, inspectors observed that there were examples where the significance of certain issues was not recognized, such that CRs were not initially written, or were written without understanding the significance of the issue and evaluations were less than adequate. NRC inspectors inquiries prompted appropriate recognition and evaluation of these issues. Examples included findings for failure to manage risk in reduced inventory (NCV 2009003-02),failure to conduct an adequate risk assessment for an orange risk condition (FIN 2009003), failure to revise procedures for Technical Specifications amendment (NCV 2009002-02), and loss of spent fuel pool neutron absorption capability (AV 2009008-01). These issues resulted from a lack of recognition of the impact these issues had on site systems and programs by licensee staff. Consequently, the NRC staff identified performance deficiencies and findings, and a substantive cross-cutting issue in the area of human performance at the midcycle 2009 assessment. The inspectors concluded that performance by plant staff in recognizing and addressing issues was a weakness. The licensee initiated CR-PLP-2010-358 to review this issue.
- (3) Findings No findings of significance were identified.
b.
Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that the overall performance in prioritization and evaluation of issues was acceptable, but some examples of evaluation inadequacy had occurred during the inspection period. Two findings, Inadequate Analysis of T-46 Drain Line Vibration" (FIN 2009004), and Failures of the Shutdown Cooling Flow Bypass Valve CV-3006 (NCV 2009004-06) were such examples. These issues required reevaluation to resolve. While generally acceptable, based on the issues in the inspection record, the team concluded that the rigor of evaluations was an area that the licensee should continue to focus on such as with the closure reviews that were being performed.
Higher level investigations in root cause evaluations and apparent cause evaluation received added reviews in Corrective Action Review Boards and Senior Assessment Review Boards. These reviews added value.
- (1) Observations Condition Report Closure by the Originator/Evaluator Inspectors noted on some CRs that the closure review was performed by the same individual who initiated and evaluated the issue. This was permitted by the process when a supervisor delegated authority for the review. This practice presents a vulnerability to a poor evaluation by eliminating an independent review. At the time of the inspection, the CAP staff was reviewing 100 percent of CR closures. This provided independence in the review, although the Entergy procedure only required a review of 25 percent of CR closures.
- (2) Findings No findings of significance were identified.
c.
Effectiveness of Corrective Actions
- (1) Overall, the licensee was effectively implementing corrective actions. Inspectors identified few examples where corrective actions, once specified, were ineffective.
More often ineffectiveness resulted from shortcomings in evaluations. One example of ineffective actions was identified as failure to completely implement a Technical Specification amendment when a procedure change was necessary. As part of the review of corrective action effectiveness, the inspectors performed a 5 year review of actions to address recurring service water system health concerns and issues with vendor control. The inspectors reviewed corrective action documents and interviewed personnel. The inspectors noted progress had been made addressing both areas; however, some corrective actions to ensure further improvement remained open.
- (2) Findings No findings of significance were identified.
B.
Assessment of the Use of Operating Experience
.1 Inspection Scope
The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures and completed evaluations of OE issues and events, interviewed individuals with respect to the use of OE, attended several meetings that involved discussions of OE, and reviewed a self-assessment of the OE program. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of the OE, were identified and effectively implemented in a timely manner.
.2 Assessment
The inspectors noted that screening of OE was performed frequently via teleconferencing between the site, fleet, and company headquarters. The inspectors believed that OE was adequately reviewed at the site. The inspectors noted that root cause reports and apparent cause evaluations included discussions of OE. There were several previous findings that noted deficiencies in the OE program, but these were addressed through programmatic and procedure changes including the transition from NMC to Entergy.
.3 Findings
No findings of significance were identified.
C.
Assessment of Self-Assessments and Audits
.1 Inspection Scope
The inspectors reviewed the audit and self-assessment programs procedures and schedules for completed and planned assessments. By reviewing a sample of audits and assessment reports, inspectors evaluated the staffs ability to perform departmental assessments and audits. The reports were reviewed for how issues were resolved including use of the CAP. Inspectors also discussed audits and self-assessments with licensee staff members.
.2 Assessment
The procedures and schedules appeared to comprise a program capable of reviewing important processes in a manner to evaluate station performance. Based on the sample reviewed, inspectors concluded that reviews were performed by knowledgeable individuals and were critical assessments of the subject areas. Where issues were identified, corrective actions were initiated commensurate with the significance and included writing CRs for conditions adverse to quality.
.3 Findings
No findings of significance were identified.
D.
Assessment of Safety Conscious Work Environment
.1 Inspection Scope
The inspectors assessed the licensees safety conscious work environment (SCWE)through the reviews of the facilitys ECP implementing procedures, discussions with the manager of the ECP, interviews with personnel from various departments, and reviews of CRs. The inspectors also reviewed the results from a 2009 Entergy Fleet Safety Culture Survey.
.2 Assessment
The licensee maintains an accessible, functioning ECP program, promotes a SCWE for employees, and periodically assesses employee attitudes though internal surveys and an external safety culture assessment by an Entergy contractor. The survey was conducted at all Entergy plants in October of 2009. Palisades had a high response rate by employees and positive responses overall. The results were tabulated into scoring on a scale of 1 to 5. All the survey results were available for specific questions and from organizational units for analysis. The licensee was developing an action plan to utilize the survey results. Based on the CRs generated at the plant, discussions with employees, and survey results, the SCWE at the plant appeared adequate and no concerns were identified by the inspectors.
.3 Findings
No findings of significance were identified.
4OA6 Management Meetings
Exit Meeting Summary
On January 28, 2010, the inspectors presented the inspection results to C. Schwarz and other members of the licensee staff. The licensee acknowledged the issues presented.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
Chris Schwarz
Entergy/Site Vice President
Tom Kirwin
Entergy/Plant General Manager
Al Blind
Entergy/Engineering Director
Bart Nixon
Entergy/Training Manager
David Hamilton
Entergy/Nuclear Safety Assurance Director
Entergy/Licensing Manager
Bill Ford
Entergy/Maintenance Manager
Bob Van Wagner
Entergy/Program Engineering Manager
Pat Russell
Entergy/System Engineering Manager
Judy Ford
Entergy/CA&A Manager
Jim Leto
Entergy/Maintenance Superintendent
John Walker
Entergy/Quality Assurance Supervisor
Ernie Chatfield
Entergy/CA&A
Ryan Prescott
Entergy/CA&A
Jim Miksa
Entergy/Operations Asst Manager
Terry Davis
Entergy/ Licensing Specialist
Chuck Sherman
Entergy/RP Manager
Joyce Keller
Entergy/Training IT
Todd Shewmaker
Entergy/Chemistry Manager
Ron Scudder
Entergy/Operations DPIC
Chuck Sherman
Entergy/Radiation Protection Manager
Chuck Scott
Entergy/Human Resources Manager
Tim OLeary
Entergy/ECI Program Manager
Don Bemis
Entergy/System Engineer
Barb Dotson
Entergy/Licensing
Nuclear Regulatory Commission
R. Lerch
NRC Project Engineer
T. Taylor
NRC Resident Inspector
J. Cassidy
NRC Reactor Inspector
P. Cardona-Morales
NRC Reactor Inspector
D. Jones
NRC Reactor Inspector
J. Giessner
NRC Branch Chief
J. Ellegood
NRC Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None