IR 05000269/2015007
| ML15146A216 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/26/2015 |
| From: | Masters A Reactor Projects Branch 7 |
| To: | Batson S Duke Energy Carolinas |
| References | |
| IR 2015007 | |
| Download: ML15146A216 (16) | |
Text
UNITED STATES May 26, 2015
SUBJECT:
OCONEE NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000269/2015007, 05000270/2015007, 05000287/2015007
Dear Mr. Batson:
On April 30, 2015, the U. S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Oconee Nuclear Station Units 1, 2, and 3 and discussed the results of this inspection with you and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.
Based on the inspection samples, the inspection team determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.
The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.
Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, 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 the 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/
Anthony D. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55
Enclosure:
INSPECTION REPORT 05000269/2015007, 05000270/2015007, and 05000287/2015007 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55 Report Nos.: 05000269/2015007, 05000270/2015007, 05000287/2015007 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station, Units 1, 2 and 3 Location: Seneca, SC 29672 Dates: April 13 - 17, 2015 April 27 - 30, 2015 Inspectors: J. Worosilo, Senior Project Engineer, Team Leader R. Rodriguez, Senior Project Engineer S. Ninh, Senior Project Engineer D. Terry-Ward, Construction Inspector Approved by: A. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000269/2015007, 05000270/2015007, 05000287/2015007; April 13, 2015 - April 30, 2015;
Oconee Nuclear Station Units 1, 2 and 3; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by three senior project engineers and a construction inspector.
No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Rev. 5.
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience (OE) usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
.1 Assessment of the Corrective Action Program
a. Inspection Scope
The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of the problem investigation program (PIPs). To verify that problems were properly identified, appropriately characterized and entered into the CAP, the inspectors reviewed PIPs that were issued between April 2013 and April 2015, including a detailed review of selected PIPs associated with the following risk-significant systems: reactor protection system, safe shutdown facility (SSF) and emergency feedwater system. Where possible, the inspectors independently verified that the corrective actions were implemented. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of PIPs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These PIPs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected PIPs, verified corrective actions were implemented, and attended meetings where PIPs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors conducted plant walkdowns within the selected systems listed above and other plant areas to assess the material condition and to identify any deficiencies that had not been previously entered into the CAP. The inspectors reviewed PIPs, maintenance history, corrective actions (CAs), completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.
The inspectors conducted a detailed review of selected PIPs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the PIPs and the guidance in licensee procedures Nuclear System Directive (NSD)212, Cause Analysis, Rev. 28 and NSD 208 Problem Investigation Program, Rev. 42.
The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence for significant conditions adverse to quality.
The inspectors reviewed selected industry OE items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.
The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP.
The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included PIP screening meetings and Performance Improvement and Oversight Committee (PIOC) meetings.
Documents reviewed are listed in the Attachment.
b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating PIPs as described in licensee procedure NSD 208 Problem Investigation Program Rev. 42, managements expectation that employees were encouraged to initiate PIPs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.
Problem Prioritization and Evaluation Based on the review of PIPs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the PIP severity level determination guidance in NSD 208, Problem Investigation Program, Rev. 42. Each PIP was assigned a priority level at the Central Screening Team (CST) meeting and adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with NSD 212, Cause Analysis, Rev. 28.
Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that, overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence, in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors examined the licensees use of industry OE to assess the effectiveness of how external and internal OE information was used to prevent similar or recurring problems at the plant. In addition, the inspectors selected OE documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal OE items, etc.) which had been issued since April 2013, to verify whether the licensee had appropriately evaluated each notification for applicability to the Oconee Nuclear Station, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.
b. Assessment Based on a review of selected documentation related to operating experience issues, the inspectors determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes.
Operating experience issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in all root cause evaluations in accordance with licensee procedure NSD 212, Cause Analysis, Rev. 28.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NSD 607, Self Assessments and Benchmarking, Rev. 19.
b. Assessment The inspectors determined that the scopes of assessments and audits were adequate.
Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that PIPs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate.
c. Findings
No findings were identified.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
During the course of the inspection, the inspectors assessed the stations safety-conscious work environment (SCWE) through review of the stations employee concerns program (ECP) and interviews with various departmental personnel. The inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
b.
Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
c. Findings
No findings were identified.
4OA6 Exit
Exit Meeting Summary
On April 30, 2015, the inspectors presented the inspection results to Mr. Batson and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- S. Batson, Site Vice President
- A. Breland, Corrective Action Coordinator
- J. Bryan, Engineering
- E. Burchfield, General Manager Engineering
- M. Carroll, OPS Human Performance Manager
- E. Cleveland, I&C Engineering/Cyber Program Manager
- P. Culbertson, Manager NOS
- C. Duntom, Site Support Director
- P. Fish, Operations Manager
- L. Hancox, Employee Concerns
- R. Matherson, Performance Improvement Manager
P. Metler - PI INPO Coordinator
- T. Patterson, Organization Effectiveness Director
- T. Ray, Plant Manager
J. Smith - Regulatory Affairs
- P. Street, Site Emergency Preparedness (EP) Manager
- C. Wasik, Regulatory Affairs Manager