IR 05000315/2003015
| ML040340485 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/02/2004 |
| From: | Eric Duncan NRC/RGN-III/DRP/RPB6 |
| To: | Nazar M American Electric Power Co |
| References | |
| IR-03-015 | |
| Download: ML040340485 (27) | |
Text
ary 2, 2004
SUBJECT:
D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000315/2003015; 05000316/2003015
Dear Mr. Nazar:
On December 19, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the D. C. Cook Nuclear Power Plant, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on December 19, 2003, 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 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. The team concluded that in general, problems were being properly identified, evaluated, and corrected. Some positive observations during this inspection may be the result of your recently developed recovery plan for the corrective action program that was still in the process of being implemented at the end of this inspection. However, during this inspection, several examples of minor problems were identified, including issues entered into the corrective action program without the proper significance categorization, a lack of rigor in operating experience reviews, and an inadequate root cause investigation. In addition, a number of significant corrective action program concerns were identified by the NRC during other inspections since the last Problem Identification and Resolution inspection, which indicated that your actions to address the previously identified corrective action program concerns have not been effective. In accordance with 10 CFR 2.790 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). 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 Duncan, Chief Branch 6 Division of Reactor Projects Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74
Enclosure:
Inspection Report 05000315/2003015; 05000316/2003015 w/Attachment: Supplemental Information
REGION III==
Docket Nos: 50-315; 50-316 License Nos: DPR-58; DPR-74 Report No: 05000315/2003015; 05000316/2003015 Licensee: American Electric Power Company Facility: D. C. Cook Nuclear Power Plant, Units 1 and 2 Location: 1 Cook Place Bridgman, MI 49106 Dates: December 8 through December 19, 2003 Inspectors: A. Dunlop, Reactor Engineer, DRS I. Netzel, Resident Inspector, D.C. Cook F. Ramirez, Reactor Engineer, DRP S. Sheldon, Reactor Engineer, DRS Approved by: Eric R. Duncan, Chief Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000315/2003015; 05000316/2003015; 12/8/2003-12/19/2003; D. C. Cook Nuclear Power
Plant, Units 1 and 2; Baseline Inspection of the Identification and Resolution of Problems.
The inspection was conducted by three region-based inspectors and one resident inspector.
No findings of significance were identified. The NRC's 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 low. Performance Assurance and self assessment reports identified issues for the plant to resolve, including issues with corrective action implementation. The significance level of identified problems was appropriately characterized in most cases.
Root cause evaluations were thorough and appropriate corrective actions for significant conditions adverse to quality were identified. However, several examples were identified by the licensee where corrective actions to prevent recurrence of significant conditions adverse to quality were not effective. An adverse performance trend in the areas of root cause identification and corrective action implementation was identified during the previous Problem Identification and Resolution (PI&R) inspection. The inspectors determined that corrective action program performance issues continued to occur in the areas.
The inspectors developed the following additional observations:
- The inspectors identified a vulnerability in the corrective action program where operating experience (OPEX) information may not receive appropriate management attention since OPEX issues were categorized, by procedure, with low significance.
- A more thorough assessment of issues associated with ineffective corrective actions was an element of the corrective action program that could be strengthened to prevent the recurrence of issues.
- The implementation of a recovery plan to improve the performance of the corrective action program has shown some positive results. However, sustained performance will be necessary for the program to be effective in adequately resolving problems.
- Through interviews and observations, the inspectors concluded that the licensee had established a safety-conscious work environment where people were not reluctant to raise issues.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
.1 Effectiveness of Problem Identification
a. Inspection Scope
The inspectors reviewed NRC inspection report findings issued over the last 2 years, selected corrective action documents, Performance Assurance (PA) assessments, self assessments, operating experience reports, and trend assessments to determine if problems were being entered into the corrective action program (CAP) at the proper threshold. The inspectors also conducted focused plant walkdowns of reactor protection and safeguards logic and actuation cabinets to ensure that equipment problems were entered into the corrective action system.
b. Issues In general, the plant identified issues and entered them into the corrective action program at an appropriate level. The licensee appropriately used the CAP to document instances where previous corrective actions were ineffective or inappropriate. For example, Category 1 condition report (CR) 03275041 was initiated when it was determined that the corrective actions implemented following the previous Problem Identification and Resolution (PI&R) inspection were not effective in improving CAP performance. The inspectors also noted the following items:
b.1 Identification Threshold The licensee had defined an adequate threshold for the identification of issues to be entered into the CAP in D. C. Cook Procedure PMI-7030, Corrective Action Program.
Corrective action documents were identified as action requests (ARs) or CRs. The generation rate for ARs/CRs was 7,130 Category 1, 2, 3, and 4 condition reports in 2002 and 7,276 Category 1,2 ,3 and 4 CRs in 2003. Both the number and significance level distribution of these condition reports appeared to be appropriate for the facility.
b.2 Operating Experience The inspectors reviewed a sample of industry operating experience (OPEX) reports and concluded that the licensee was appropriately including the issues in the CAP. The inspectors noted, however, that OPEX-related CRs had their own specific category of "OE" in the CAP system, and that the corrective actions resulting from OPEX report reviews were categorized as "X". Categories "OE" and "X" were the least significant category in the CAP system. Refer to Section 4OA2.2.b.3 for additional information on operating experience.
b.3 Performance Assurance The inspectors reviewed a sample of PA assessment reports from the past 2 years and determined that the PA staff, in general, was effectively identifying plant performance issues including issues with implementation of the CAP. A recent PA assessment of the corrective action program concluded that CR initiation was effective with some weaknesses. However, CR evaluation and corrective actions were considered marginally effective with significant weaknesses. This assessment was consistent with NRC inspection findings since the last PI&R inspection.
.2 Prioritization and Evaluation of Issues
a. Inspection Scope
The inspectors reviewed inspection reports and corrective action documents to verify that identified issues were appropriately characterized and prioritized in the CAP.
Inspectors attended management meetings to observe the assignment of CR categories for current issues and the review of root, apparent, and common cause analyses; and corrective actions for existing CRs.
The inspectors conducted an independent assessment of the prioritization and evaluation of selected CRs. The assessment included a review of the category assigned, the operability and reportability determinations, the extent of condition evaluations, the cause investigations, and the appropriateness of assigned corrective actions. Other attributes reviewed by the inspectors included the quality of the licensees trending of conditions and the corresponding corrective actions. The inspectors also assessed licensee corrective actions stemming from Non-Cited Violations (NCVs) and Licensee Event Reports (LERs). This review included the controlling procedures, selected records of activities, and observation of various licensee meetings. In addition, the inspectors conducted several interviews with cognizant licensee personnel.
The inspectors reviewed several generic communications regarding industry operating experience information and observed one operating experience screening meeting to verify that known industry problems that had a potential to affect D. C. Cook were being identified and appropriately evaluated.
Information reviewed by the inspectors dated back to the previous PI&R inspection conducted in April 2002 (NRC Inspection Report 05000315/2002004(DRP);05000316/2002004(DRP)).
b. Issues The inspectors verified that the issues reviewed were properly categorized and evaluated. Details of the inspectorss observations are described in the following subsections.
b.1 Overview of Prioritization and Evaluation Process Within the licensees program, a Significant Condition Adverse to Quality (SCAQ) could be assigned as a Category 1 requiring a root cause evaluation, or as a Category 2 requiring an apparent cause evaluation. A Condition Adverse to Quality (CAQ) could be assigned as a Category 3 requiring further investigation to determine the proper corrective actions, or as a Category 4" that was determined to have minimal impact not requiring further evaluation. A Category X classification was also available for conditions that were not adverse to quality.
The corrective action process included a daily review of new CRs by an initial screening committee comprised of plant management. This group ensured that the CR had the appropriate level of review and adjusted the categorization if necessary. They also requested further information if a trend was identified. The following day, the same CRs were reviewed by a senior management screening committee, which included the Plant Manager. This committee was recently implemented as part of the site's recovery plan interim actions to address identified concerns with the CAP process. Again, the senior management committee adjusted the categorization if necessary, requested further information regarding trends, and provided feedback to the initial screening committee.
The inspectors attended some of these meetings and found that the reviews were appropriately critical and conservative. Attendees were prepared to answer questions concerning the CRs and exhibited a safety conscious attitude.
b.2 Prioritization of CRs The inspectors identified two CRs initiated in 2002 which were improperly classified in the licensees CAP system.
On February 21, 2002, the licensee initiated CR 02052030, Auto Safety Injection Blocked Status Light Illuminated. The CR documented that while in Mode 4, the operators in the Unit 2 control room identified the "Train B Auto Safety Injection Blocked" status light to be lit, indicating that the Train B safety injection function was not available. At the time, the licensee classified this CR as a Action Category 3, which was a condition adverse to quality requiring further investigation to determine the proper corrective actions. The inspectors determined that this issue met the criteria for an Action Category 2, significant condition adverse to quality, because it was an equipment failure that reasonably could have had a direct adverse affect on the safe and reliable operation of the plant if different circumstances existed. The plant condition was corrected on February 21, 2002, and the CR was closed on June 13, 2002.
On February 18, 2002, the licensee initiated CR 02049054, The CD2 Battery Charger Failed to Control Bus Voltage Resulting in Multiple Control Room Annunciators and a Large Current Loading on the Charger. At the time, the licensee classified this issue as an Action Category 3. The inspectors determined that this issue met the criteria for an Action Category 2, significant condition adverse to quality, because it was an equipment failure that reasonably could have had a direct adverse affect on the safe and reliable operation of the plant if different circumstances existed, e.g., if the plant had been operating at power.
These issues were considered minor because the licensee's prioritization of the issues as Action Category 3 rather than Action Category 2 had no actual or potential impact on safety.
b.3 Review of Operating Experience Information The inspectors determined that the licensees Operating Experience Group adequately identified, evaluated, and developed corrective actions for known industry problems that could potentially impact D. C. Cook. However, the inspectors identified the following minor issue.
Institute for Nuclear Plant Operations (INPO) Significant Operating Experience Report, SOER 02-4, Reactor Pressure Vessel Head Degradation at Davis-Besse Nuclear Power Station, evaluated under CR 02323072 lacked rigor. In assessing the safety culture of the facility, a survey of questions was posed to a small group of individuals.
The results of this survey did not appear to be statistically significant due to the very low number of responses. In addition, most of the corrective actions that resulted from the SOER 02-4 response were either not appropriately implemented, overdue, or closed without performing the prescribed actions.
The issue was considered to be minor because the inspectors did not identify any potential or actual adverse consequences which resulted from the issue.
b.4 Root Cause Evaluations and Apparent Cause Evaluations The inspectors reviewed 11 root cause evaluations and 16 apparent cause evaluations.
Most of these evaluations appeared thorough and reasonable with one exception. The apparent cause for CR 02049054, The CD2 Battery Charger Failed to Control Bus Voltage Resulting in Multiple Control Room Annunciators and a Large Current Loading on the Charger, was demonstrated to be incorrect 3 days later as documented by CR 02052070, Relay K301 Failed Causing Uncontrolled DC Voltage Output. This indicated that the root cause had not been adequately investigated before being documented.
b.5 Category X CRs A potential vulnerability identified during the previous PI&R inspection concerned the potential for an untimely operability evaluation when a CR was inappropriately designated as Category X. This was based on the licensee working a 4-day work week, such that screening meetings were only held Tuesday through Friday. As a result, if a CR was initiated and inappropriately designated as Category X on a Friday after the daily screening meeting, the next scheduled opportunity to identify the inappropriate significance level would be the following Tuesday as Operations Department personnel did not review Category X CRs.
Subsequent to this inspection, the licensee returned to a 5-day work week such that screening meetings were held on each business day. The licensee was also tracking CRs that were upgraded from Category X. The licensee review of the these upgraded CRs did not identify any operability issues. The inspectors performed an independent review and did not identify any CRs that were inappropriately designated as Category X that resulted in an untimely operability evaluation.
.3 Effectiveness of Corrective Action
a. Inspection Scope
The inspectors reviewed past inspection results, selected CRs, root cause reports, and common cause evaluations to verify that corrective actions, commensurate with the safety significance of the issues, were specified and implemented in a timely manner.
The inspectors evaluated the effectiveness of corrective actions. The inspectors also reviewed the licensees corrective actions for NCVs documented in NRC inspection reports in the past 2 years. The inspectors conducted a walkdown of reactor protection and safeguards logic and actuation cabinets to assess the material condition of the system, and to verify that the licensee appropriately identified degraded conditions within the corrective action program.
b. Issues In general, the licensees corrective actions for the samples reviewed were appropriate and appeared to have been effective. The inspectors noted that the licensee generated CRs when they identified a corrective action which was either inadequate or inappropriate.
b.1 Observations on the Effectiveness of Corrective Actions The inspectors had several observations regarding corrective actions that were not fully effective in correcting the identified issue or preventing recurrence. These observations are described below.
C The licensee initiated Category 2 CR 02139007, Steam Generator Workers Uptake of Radioactive Material, for inadequate radiological controls for steam generator eddy current testing. The licensee performed a root cause evaluation which identified human performance as the root cause. A number of worker training corrective actions were implemented to prevent recurrence. However, the licensees effectiveness review for the corrective actions determined that based on additional radiological control issues during the subsequent outage, the corrective actions were inadequate, and initiated CR 03176031 to evaluate the events in the aggregate and address common causes.
C The licensee initiated Category 2 CR 02108057, Cross-Cutting Concern Resulting From PI&R Inspection Report 2002-04, to address the cross-cutting corrective action program concern. As discussed in Section 4OA2.5 of this report, the corrective actions implemented for the previous PI&R inspection finding were not effective in improving CAP performance. This resulted in the issuance of CR 03275041, another root cause evaluation, and the subsequent CAP recovery plan that the licensee was in the process of implementing at the time of this inspection.
C As discussed in Section 4OA4 of this report, a number of issues were identified since the last PI&R inspection concerning the failure to take adequate corrective actions to prevent recurrence.
As a result of these issues, a concern exists with the implementation of corrective actions to prevent the recurrence of problems.
b.2 Practice of Closing CRs to Work Requests or Other CRs The inspectors reviewed CRs to assess whether the original issue was appropriately addressed. Previously, an NRC inspection conducted in 2003 (NRC Inspection Report 05000315/2003004 and 05000316/2003004) in accordance with Inspection Procedure 95002, "Inspection For One Degraded Cornerstone or Any Three White Inputs In A Strategic Performance Area," noted several instances where corrective actions had been repetitively closed to other CRs, closed to a lower significance document such as a Category X CR, or re-characterized in the process of being transferred to another CR.
The inspectors verified that for category 1, 2, 3, and 4 CRs, the issues identified in the initial CR was appropriately addressed in that same CR and not closed to other follow-on documents to ensure that issues and corrective actions were appropriately tracked to completion.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The inspectors conducted interviews with plant staff to assess whether there were impediments to the establishment of a safety conscious work environment. During these interviews, the inspectors used Appendix 1 to Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues, as a guide to gather information and develop insights. The inspectors also discussed the implementation of the Employee Concerns Program (ECP) and selected concerns with the licensees ECP Coordinators. Additional discussions with the ECP Coordinators focused on the integration of the ECP and CAP programs.
b.
Issues Plant staff interviewed did not express any concerns regarding a safety conscious work environment. The staff was aware of and generally familiar with the corrective action program and other plant processes including the ECP through which concerns could be raised. Further, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to address their concerns. Based on interviews, the ECP Coordinators were appropriately focused on ensuring all site individuals were aware of the program, reviewing individual concerns, and integrating where appropriate the ECP and CAP programs to resolve concerns.
.5 Resolution of Issues Identified During Last PI&R Inspection
a. Inspection Scope
The inspectors reviewed corrective actions that had been implemented to address the issues identified during the last PI&R inspection in April 2002 as documented in NRC Inspection Report 05000315/2002004(DRP); 05000316/2002004(DRP).
b. Issues During the PI&R inspection in April 2002, the inspectors identified several concerns with the implementation of the corrective action program including the following:
C A recurring issue regarding the failure to implement some corrective actions as prescribed in root cause evaluations.
C The ability to consistently identify reasonable causes for conditions adverse to quality was inadequate which could adversely impact implementation of prompt and effective corrective actions to resolve the problem.
C A review of previously documented findings revealed that an adverse performance trend existed regarding the ability to promptly and effectively resolve conditions adverse to quality. This was considered a substantive cross-cutting issue.
As a result of the NRC inspection results, the licensee initiated Category 2 CR 02108057 to address the issue with the corrective action program. The resultant root cause evaluation identified the following root causes:
C The knowledge of corrective action program requirements was inconsistent due to inadequate direction.
C Condition report corrective action closure was inadequate due to a poor verification process.
These root causes resulted in a number of corrective actions to improve the corrective action process. Some of the actions taken by the licensee included:
C Establish and communicate management expectations relative to CR quality; C Provide training on equipment causal analysis; C Develop guidelines and performance-based qualifications for evaluators and approvers; C Develop a prioritization process for CR evaluation and actions; C Provide an expectation to department managers to monitor and coach on current CR action quality expectations; C Implement an accountability process relative to CR action quality; C Develop and provide reports and indicators to managers that identifies overdue evaluations and actions, quality aspects, etc.;
C Expand the Corrective Action Review Committee charter to include participation requirements and expand their review responsibilities; and C Modify PMP 7030 CAP.001 to require due date extensions, changes to prescribed action, etc. associated with Category 1, 2, 3 CRs, or regulatory issues to be presented to the original evaluation review group for approval.
On October 2, 2003, the licensee initiated Category 1 CR 03275041, which stated that there were significant weaknesses in the corrective action program that need to be understood and corrected. This action was the result of both internal and external assessments of the program. It was concluded that the actions put in place for the previously identified concerns with the corrective action program were not effective in preventing the recurrence of problems. A root cause evaluation was conducted, which identified the following two root causes:
C Management strategic level corrective action program implementation focus was predominately reactive, did not guide the organization in setting and executing priorities in the presence of degrading programmatic performance and competing events, and did not demand accountability in meeting roles and responsibilities; and C Quality and timeliness of cause evaluation completion and corrective action implementation were inconsistent due to minimal quality expectations, a lack of peer checking, and the limited scope of corrective action review boards.
Several contributing causes were also identified in the root cause evaluation. In addition, as part of establishing a successful corrective action program, the licensee identified 13 critical attributes of an excellent program. The licensee then performed a gap analysis to evaluate how the corrective action program in place compared to these attributes. This analysis determined that most of the attributes were not being met. As a result of the root cause evaluation, the critical attribute gap analysis, and the new senior management team, the licensee was in the process of implementing a corrective action program recovery plan. Interim actions to address shortcomings with the corrective action program were already in place at the time of the inspection.
Based on the actions the licensee has taken to date, the inspectors had some positive observations during this inspection. However, demonstrated sustained performance will be necessary for the program to be effective in adequately resolving problems identified at the plant.
4OA4 Cross-Cutting Issues
a. Inspection Scope
The inspectors reviewed NRC inspection reports issued since June 1, 2002, to determine if the adverse performance trend in problem identification and resolution that was identified in inspection report 05000315/2002004(DRP); 05000316/2002004(DRP)had improved.
b. Issues The inspectors determined that corrective action program performance issues continued to occur. The following findings associated with the corrective action program were documented since June 1, 2002:
b.1 Initiating Events Cornerstone
- In December 2002, inspectors identified a Green finding and associated Non-Cited Violation for the failure to assure that prompt corrective actions were taken to address age-related failures of reactor control instrumentation power supplies to prevent repetition of power supply failures, a significant condition adverse to quality. This issue was self-revealed on May 12, 2002, when an automatic reactor trip of Unit 2 occurred due to the failure of redundant 24-volt direct current power supplies in reactor control instrumentation cabinet 2-PS-CGC-16. The failure of both power supplies caused the number 21 steam generator feedwater regulating valve to close. Unit 2 subsequently tripped on low steam generator water level coincident with low feedwater flow (Green; NCV 05000316/2002009-01).
- In December 2002, inspectors identified a Green finding and associated Non-Cited Violation for the failure to take corrective action to preclude the repetition of reactor control instrumentation 24-volt direct current power supply failures. Specifically, the licensee failed to perform weekly verification of control group power supplies to ensure that the "power available" status lights were lit.
This corrective action was identified by the licensee in response to the Unit 2 reactor trip on May 12, 2002, which was caused by the failure of redundant power supplies in reactor control instrumentation cabinet 2-PS-CGC-16. The licensee subsequently performed this check on November 22, 2002, and discovered a failed 24-volt direct current power supply in Unit 1 cabinet 1-PS-CGC-16 (Green; NCV 05000316/2002009-02).
- In June 2003, inspectors identified a Green finding and associated Non-Cited Violation for failure to take effective corrective actions to address age-related failures of reactor control instrumentation power supplies and prevent an automatic Unit 2 reactor trip on February 5, 2003, due to the failure of similar power supplies (Green; NCV 05000316/2003006-03).
b.2 Mitigating Systems Cornerstone
- In December 2002, inspectors identified a Green finding and associated Non-Cited Violation for the failure to assure that corrective actions were taken to preclude repetition of emergency diesel generator (EDG) starting air system relay failures, a significant condition adverse to quality. This issue was self-revealed when the failure of a starting air system relay for the Unit 2 AB EDG occurred on October 16, 2002, causing the engine to roll without a valid start signal. The inspectors subsequently identified that appropriate corrective actions to prevent repetition had not been taken following two previous age-related EDG air start relay failures in January 1999 and September 2000 (Green; NCV 05000315/2002009-03; NCV 05000316/2002009-03).
C In March 2003, inspectors identified a Green finding and associated Non-Cited Violation for the failure to take adequate corrective action to revise Procedure 12-MHP-5021-056-007, "Turbine-driven Auxiliary Feedwater Pump Trip and Throttle Valve Linkage Adjustment," to include the manufacturer's recommendations regarding the set-up of the turbine trip throttle valve (Green; NCV 05000315/2003004-01; NCV 05000316/2003004-01).
C In March 2003, inspectors identified a Green finding and associated Non-Cited Violation for the failure to take corrective action to ensure that only turbine trip throttle valve latch hooks with the correct geometry would be installed in the turbine-driven auxiliary feedwater pumps after determining that the incorrect part had been supplied by the manufacturer (Green; NCV 05000315/2003004-02; NCV 05000316/2003004-02).
C In June 2003, inspectors identified a Green finding and associated Non-Cited Violation for the failure to take effective corrective actions to address Unit 2 CD EDG load oscillations that occurred on November 2, 2002, to prevent recurrence of these oscillations on January 26, 2003 (Green; NCV 05000316/2003006-01).
C In July 2003, inspectors identified a Green finding and associated Non-Cited Violation for the failure to resolve Technical Specification interpretation inconsistencies associated with the total required volume in the emergency diesel generator fuel oil day tanks in a timely manner. These inconsistencies were identified by the licensee in August 2000, however, as of July 11, 2003, this issue remained unresolved (Green; NCV 05000315/2003007-01; NCV 05000316/2003007-01).
b.3 Barrier Integrity Cornerstone C In December 2002, inspectors identified a Green finding and associated Non-Cited Violation for the failure to identify and take appropriate corrective actions to preclude the failure of four Unit 1 reactor coolant system pressure boundary charging line check valves (Velan Model B10-3114B-13M), which were at risk of common cause failure due to industry identified design and manufacturing defects, a significant condition adverse to quality. This issue was self-revealed when the check valves were all found to be stuck in either the full or partially open position during radiographic nonintrusive testing in May 2002.
(Green; NCV 05000315/2002009-04).
The inspectors determined that each of these issues was due to a common causal factor associated with the failure to promptly and effectively resolve conditions adverse to quality. Although the individual findings highlighted were of very low safety significance, the findings could have had a credible impact on safety by affecting the availability, reliability, operability or functionality of mitigating equipment and by affecting public radiation safety.
4OA6 Management Meetings
.1 Exit Meeting Summary
The inspectors presented the inspection results to Mr. M. Nazar and other members of licensee management at the conclusion of the inspection on December 19, 2003. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
The licensee indicated that no proprietary information was provided to the inspectors.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Finissi, Plant Manager
- M. Horvath, Manager, Employee Concerns Program
- J. Jensen, Senior Vice President
- J. Kobyra, Learning Organization Director
- E. Larson, Work Management Director
- B. Mann, Manager, Regulatory Affairs
- M. Nazar, Chief Nuclear Officer
- S. Simpson, Operations Director
- L. Weber, Performance Assurance Director
- D. Wood, Manager, Radiation Protection/Environmental
- J. Zwolinski, Engineering & Regulatory Affairs Director
Nuclear Regulatory Commission
- E. Duncan, Chief, Branch 6, Division of Reactor Projects
- B. Kemker, Senior Resident Inspector
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None Attachment