IR 05000269/2003009
| ML032260552 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/08/2003 |
| From: | Haag R NRC/RGN-II/DRP/RPB1 |
| To: | Rosalyn Jones Duke Energy Corp |
| References | |
| IR-03-009 | |
| Download: ML032260552 (19) | |
Text
ust 8, 2003
SUBJECT:
OCONEE NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000269/2003009, 05000270/2003009, AND 05000287/2003009
Dear Mr. Jones:
On July 11, 2003, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oconee Nuclear Station. The enclosed report documents the inspection findings which were discussed on July 10, 2003, with you and other members of your staff.
This inspection was an examination of activities conducted under your licenses as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating licenses. Within these areas, the inspection involved a selected examination of procedures and representative records, observation of activities, and interviews with personnel.
On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that in general, problems were properly identified, evaluated and resolved within the corrective action programs. However, some problems were noted with unclear or incomplete corrective actions, the thoroughness of problem assessment, and categorization of issues which may have affected the resolution of issues in the corrective action program.
DEC 2 In accordance with 10 CFR 2.790 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//
Robert C. Haag, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-269, 50-270, 50-287 License Nos. DPR-38, DPR-47, DPR-55
Enclosure:
NRC Inspection Report 05000269/2003009, 05000270/2003009, and 05000287/2003009 w/Attachment: Supplemental Information
DEC 3
REGION II==
Docket Nos: 50-269, 50-270, 50-287 License Nos: DPR-38, DPR-47, DPR-55 Report No: 05000269/2003009, 05000270/2003009, 05000287/2003009 Licensee: Duke Energy Corporation Facility: Oconee Nuclear Station, Units 1, 2, and 3 Location: 7800 Rochester Highway Seneca, SC 29672 Dates: June 23, 2003 - July 11, 2003 Inspectors: G. MacDonald, Senior Project Engineer K. ODonohue, Senior Operations Engineer A. Hutto, Resident Inspector M. Scott, Senior Reactor Inspector Approved by: Robert Haag, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
OF ISSUES
IR 05000269/2003-009, 05000270/2003-009, 05000287/2003-009; 06/23/2003 - 07/11/2003;
Oconee Nuclear Station, Units 1, 2, and 3; additional baseline inspection of the problem identification and resolution program.
The inspection was conducted by a senior project engineer, a senior operations engineer, a senior reactor inspector, and a resident inspector. 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 team identified that the licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution. The licensee maintained a low threshold for identifying problems as evidenced by the continued large number of Problem Investigation Process reports (PIPs) entered annually into the CAP. The inspectors independent review did not identify significant adverse conditions which were not in the CAP for resolution. Evaluation and prioritization of problems was generally effective; although, one example was noted where an evaluation did not thoroughly examine the potential for generic implications. Corrective actions specified for problems were generally adequate; although, several examples were noted where corrective actions were not complete or not comprehensive. Audits and self-assessments continued to identify issues; however, some examples were noted where the issues were not correctly classified for resolution. Previous non-compliance issues documented as non-cited violations were properly tracked and resolved via the CAP. Personnel at the site felt free to raise safety concerns to management and to resolve issues via the CAP.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a. Effectiveness of Problem Identification
- (1) Inspection Scope The inspectors reviewed Problem Investigation Process reports (PIPs) for issues across the reactor safety cornerstones to determine if problems were being properly identified and entered into the corrective action program (CAP) for resolution. The review was primarily focused on selected systems and plant program improvement initiatives. The systems reviewed included the high pressure injection (HPI) system, the reactor building cooling unit (RBCU) portion of the low pressure service water system, the emergency feedwater (EFW) system, and the standby shutdown facility (SSF). The plant programs reviewed included the Calculation Enhancement Program, the Emergency Operating Procedures (EOP) Initiative, the Time Critical Operator Actions (TCOA) Program, and the Operable But Degraded/Non-Conforming Item (OBD/NCI) Program. For the program reviews, the inspectors focused on determining if the program scopes had been reduced and if problems identified during program implementation were being entered into the CAP for evaluation and resolution.
System health reports, trend reports, open PIPs, work orders, and planned modifications for the systems were reviewed. Plant walkdowns of the accessible portions of the systems were performed to determine if deficiencies existed that had not been entered into the CAP. No walkdown was performed for the RBCUs. The inspectors discussed system status with system engineers and other plant personnel.
Selected audits and self-assessments were reviewed to determine if identified issues were entered into the CAP. Employee concerns issues were reviewed to determine if identified problems were entered into the CAP. CAP status tracking and performance trending data were reviewed to determine if there was any significant change in the rate of PIP generation. The interface between the procedure change process and the CAP was reviewed to determine if PIPs were used for identified procedure problems.
Documents reviewed are listed in the Attachment to this report.
- (2) Assessment During the system reviews and walkdowns of the accessible portions of the HPI, SSF, and EFW systems, the inspectors found that the system deficiencies were being identified and placed in the CAP and that the system engineers were appropriately tracking and trending these issues. The inspectors did not find any significant conditions adverse to quality during the system walkdowns; however, two items were noted for which PIPs had not been written. The inspectors identified that the flow indicators for the motor driven EFW pump recirculation lines were not reading zero gallons per minute with no flow. Unit 2 was reading approximately 30 gpm while Units 1 and 3 were reading significantly below the zero mark. The inspectors also observed that the level of general housekeeping around the turbine driven EFW pumps was not commensurate with the rest of the system. PIPs were subsequently written for these two issues. During interviews, the inspectors noted that not all engineers were making walk down of the normally non-accessible portions of their systems a priority during outages, when those portions of the systems could be walked down.
The EOP Initiative effort resulted in a complete rewrite and reformatting of the EOPs for all three units. Implementation of the new revisions took place in December of 2001.
The inspectors determined that the EOP Initiative scope was not reduced and that PIPs were initiated for problems which were identified during program implementation. The Calculation Enhancement Program was examined and the inspectors determined that the scope had not been reduced and that PIPs were generated for identified problems.
The inspectors reviewed the licensees program for managing time critical operator actions (TCOA) with respect to its interface with the CAP. The inspectors selected a sample of TCOAs tracked by the program and verified that corrective actions associated with eliminating or minimizing the burden of these TCOAs were captured by PIPs and that these PIPs were appropriately prioritized. The inspectors noted that corrective actions for the most significant TCOAs were being managed appropriately with modifications that were either completed or scheduled for upcoming unit outages. The inspectors reviewed the OBD/NCI program which contained items that are degraded but operable under Generic Letter 91-18 guidance. Many of these were operator actions that required modifications (NSMs) to reduce the operator activities during an accident scenario. Selected EFW and low pressure injection (LPI) OBD/NCIs, status documents, and computer tracking data bases were reviewed and the inspectors determined that PIPs were generated for these NCIs. The inspectors determined that PIPs were used to evaluate the OBD/NCI items with resolution planned via the plant modification process and that most of the modifications had been scheduled for installation. In accordance with procedure Nuclear Station Directive (NSD) 203, Operability, the licensee was reviewing the aggregate NCI list and PIP details after each outage for operational impact.
For the audits and self-assessments reviewed, the inspectors verified that the issues raised during the assessments were entered into the CAP for resolution. The inspectors noted that PIPs were generated for the technical issues sampled from the employee concerns files. CAP performance data and trending was reviewed and the inspectors noted that PIP generation rate had not reduced. As of July 2003, over 5000 PIPs had been generated for this year. Based on review of EOP PIPs, deleted PIPs, and personnel interviews it was not clear that site personnel had a consistent threshold for selecting either a PIP or a Procedure Change Request for resolving procedure problems. The team identified that the licensee was effective at identifying problems and entering them into the CAP for resolution. The licensee maintained a low threshold for identifying problems as evidenced by the continued large number of PIPs entered annually into the CAP. The inspectors independent review did not identify adverse conditions which were not in the CAP for resolution.
b. Prioritization and Evaluation of Issues
- (1) Inspection Scope The inspectors reviewed PIPs in all action category levels (1-4) to determine if the identified problems were properly prioritized in accordance with procedure NSD-208, Problem Investigation Process. The action categories (1 through 4) were defined in NSD 208 and were numbered based on decreasing significance. Action Category 1 PIPs are significant conditions adverse to quality (CAQs) that required formal root cause evaluations. Action Category 2 PIPs are defined as CAQs for which management could use its discretion in deciding whether to perform a formal root cause evaluation. Action Category 3 PIPs are problems for which an apparent cause analysis is sufficient to correct the immediate problem. Action Category 4 PIPs are low level CAQs or conditions not adverse to quality, neither of which require any type of causal evaluation.
The inspectors attended daily status meetings and several PIP screening meetings to observe licensee problem processing and issue categorization.
Selected licensee audits and self-assessments were reviewed to determine if identified issues were correctly classified for resolution in accordance with procedure NSD-607, Self-Assessments. Action Category 1, 2, and 3 PIPs were reviewed to assess the adequacy of the root/apparent cause evaluation of the selected problems. The inspectors reviewed the root/apparent cause evaluations against the description of the problem in the PIP and the guidance in procedure NSD-212, Cause
Analysis.
Documents reviewed are listed in the Attachment to this report.
- (2) Assessment The inspectors determined that PIPs were generally categorized correctly. The root/apparent cause evaluations for the PIPs reviewed were generally adequate; however, one example (PIP O-02-3709, Reinsertion of alternate boron dilution) was noted which was not thorough and did not appear to consider potential generic aspects of the root cause. PIP O-99-04113 [Licensee Event Report (LER) 50-269/99-07, LP-15 and 16 powered off of non-safety related power] was incorrectly listed as category 3.
The license corrected the PIP to Category 1.
PIP O-02-3709 addressed inappropriate use of the alternate boron dilution flowpath during response to small break loss of coolant accident (LOCA), LER 50-269/02-04, Potential loss of Safety Function Due to Inadequate Design Documentation and Procedure Change. The small break LOCA EOP had been previously revised to delete the use of the alternate dilution flowpath; the large break LOCA procedure was unaffected. When the EOP two column rewrite initiative revised the two LOCA procedures, the procedures were combined and the use of the alternate boron dilution flowpath was incorrectly re-introduced. PIP O-02-3709 evaluation indicated that the error was an isolated instance in the EOP initiative, but did not provide a basis for this conclusion. The evaluation did not thoroughly explore the failure of the review and validation effort to identify the error or describe any assessment of the potential extent of the condition to assess generic implications for the error. The PIP corrective actions included the development of an EOP step bases document which would provide validation of all EOP procedure steps. The LER did not identify this as a corrective action. The lack of thoroughness of the EOP procedure error evaluation was mitigated by the fact that the proposed PIP corrective actions would address generic concerns.
The enforcement aspects of this issue will be addressed in a subsequent Inspection report with the dispositioning of LER 50-269/02-04.
Audits and self-assessments generally categorized identified issues correctly: however, several examples of incorrect assessment item categorization were noted. PIPs O-02-1260 and O-02-1470 classified incorrect peer check performance issues as areas for improvement. The inspectors determined that the peer checks were not performed as described in procedure OMP 1-02, Rules of Practice. Incorrect peer checks should have been classified as deviations per the definition found in procedure NSD 607 Self-Assessments. Two assessments for the OBD/NCI program were reviewed in which the licensee had assessed the aggregate effect of the NCIs but did not determine the cumulative risk of the NCIs. Several daily status meetings and PIP screening meetings were observed and the inspectors noted that problem categorization and prioritization met procedure requirements. The team determined that evaluation and prioritization of problems was generally effective; although, one example was noted where an evaluation did not thoroughly examine the potential for generic implications. Audits and self-assessments continued to identify issues; however, some examples were noted where the issues were not correctly classified for resolution.
c. Effectiveness of Corrective Actions
- (1) Inspection Scope The inspectors reviewed PIPs to assess the adequacy of the corrective actions applied to the adverse conditions documented in the PIP. The sample selected included PIPs related to the systems and program initiatives reviewed in report section 4OA2.a.(1),
PIPs related to issues documented in NRC Inspection Reports, and a sampling of the oldest PIPs. The review focused on whether the identified corrective actions were appropriate to the problem description and the root/apparent cause evaluation. For the review of the oldest PIPs, the inspectors focused on verification that there was a valid basis for the delay in correcting the identified problems. Individual corrective actions were sampled for verification that actions had been satisfactorily completed.
The CAP allowed individual corrective action closure within the PIP and transfer of the corrective action to the work control process, the modification process, and recently to the procedure revision process. This was only allowed for routine corrective actions and not for corrective action to prevent recurrence. The inspectors selected items for which PIP corrective action closeout to other processes had occurred to verify that the actions were completed or still being tracked for completion in the other systems. A sampling of deleted PIPs were reviewed to assess the basis for the deletion and if deletion was appropriate for the issue. Documents reviewed are listed in the Attachment to this report.
- (2) Assessment The inspectors determined that corrective actions specified for identified problems reviewed were generally adequate with several examples noted where corrective actions were not complete or not comprehensive. The first example was PIP O-00-2045 where corrective actions were signed off as completed when all actions had not been accomplished. The specific corrective action included preparing job performance measures (JPMs) for operator training. However, the licensee was unable to verify that the JPMs were developed. The inspectors determined that the lack of these specific JPMs was not significant and would not have prevented the operators from adequately performing required tasks. Additional training mechanisms were available to address these actions.
The second example was PIP O-01-626, where the corrective action specified was not comprehensive. This was an OBD/NCI PIP regarding use of alternate source term for post accident dose calculations. Errors were noted in the PIP regarding steam generator tube rupture (SGTR) related doses to operators. The PIP was revised to address the SGTR dose error and additional details were added to the PIP in response to inspector questions to explain how existing proceduralized dose controls would prevent overexposure when performing post accident manual actions. One example was noted (PIP O-93-677) where delay in the corrective action implementation for a modification was due to misunderstanding of which group was performing the unresolved safety question determination.
As part of the assessment of corrective action adequacy, the inspectors reviewed a sampling of deleted PIPs. Most of the deletions were due to duplicate PIPs. PIP O-02-2350 was incorrectly deleted. There was no safety significance to this issue and the PIP was re-opened. Several other PIPs were noted which did not contain an adequate basis for deletion; however, the inspectors were able to verify that the deletions were appropriate.
A sampling of deleted modifications was reviewed to determine if any PIP related modifications had been deleted and none were identified. Corrective actions for seven PIPs which had been closed out to modifications were reviewed and the inspectors verified that the modifications had been completed or were still scheduled. One example of corrective action being closed to the procedure change process was reviewed with no problems noted. Seven PIP corrective action items which had been closed out to the work request (WR)/work order (WO) process were reviewed and the inspectors noted that all WRs/WOs had been completed. The inspectors noted that several of the WRs/WOs reviewed did not have the PIP number identified in the WR/WO. This lack of PIP numbers in the WRs/WOs for PIP corrective actions closed out to the work control process was also identified by the licensees corrective action self-assessment.
The inspectors reviewed the licensees corrective action program tracking and noted that the current routine corrective action backlog was high and the timeliness of routine corrective actions was not meeting expectations. Action plans had been developed to address these aspects. Corrective actions to prevent recurrence (CAPR) backlog had previously been worked down. The inspectors noted that the licensee still maintains the process of closing non-CAPR corrective actions out by transfer to other site programs (procedure change, work control, and modification processes) without verification that the actions are completed. This practice masks the real corrective action backlog and provides less oversight of the issue than if the item had remained within the CAP and been tracked to resolution. Corrective actions specified for problems were generally adequate; although, several examples were noted where corrective actions were not complete or not comprehensive. Previous non-compliance issues documented as non-cited violations were properly tracked and resolved via the CAP.
d. Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope The inspectors interviewed site personnel regarding utilization of the CAP for problem resolution to determine if a safety-conscious work environment existed at Oconee Nuclear Station (ONS). Concerns resolution program files were also reviewed to determine if identified issues were entered into the CAP for resolution.
- (2) Assessment The inspectors interviewed various levels of personnel from site departments that perform regulated activities including the Oconee concerns resolution program manager regarding the use of the CAP for problem resolution. No reluctance to identify safety concerns was noted, and all interviewed personnel felt free to initiate PIPs into the CAP for resolution of problems. Concerns resolution files for 2002 and 2003 were sampled and the inspectors determined that when concerns were substantiated and technical issues were identified, PIPs were initiated for resolution. The inspectors concluded that a safety-conscious work environment was maintained at ONS.
4OA6 Meetings, Including Exit
On July 10, 2003, the inspectors presented the inspection results to Mr. Ron Jones, Site Vice President, and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during this inspection.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Jones, Site Vice President
- B. Hamilton, Station Manager
- S. Batson, MCE Engineering Manager
- L. Nicholson, Regulatory Compliance Manager
- M. Ramey, Maintenance Manager
- P. Stovall, SRG Manager
- E. Burchfield, DBG Engineering Supervisor
- N. Clarkson, Regulatory Compliance Senior Engineer
- H. Dummeyer, Corrective Action Group Engineer
- R. Matheson, Corrective Action Lead Engineer
- J. Weast, Regulatory Compliance Engineer
- J. Smith, Regulatory Compliance Technician
NRC Personnel
- E. Riggs, Resident Inspector, RII
- M. Shannon, Senior Resident Inspector, RII
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE
Opened and Closed
NONE
Closed
NONE
Discussed
50-269/02-04 LER Potential Loss of Safety Function Due to Inadequate Design Documentation and Procedure Change