IR 05000315/2011008
| ML111741268 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/23/2011 |
| From: | Jamnes Cameron NRC/RGN-III/DRP/B6 |
| To: | Weber L Indiana Michigan Power Co |
| References | |
| IR-11-008 | |
| Download: ML111741268 (22) | |
Text
June 23, 2011
SUBJECT:
D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000315/2011008; 05000316/2011008
Dear Mr. Weber:
On May 20, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) team inspection at your D. C. Cook Nuclear Power Plant, Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on May 20, 2011, with you and other 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, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
The inspection team concluded that on the basis of the sample selected for review, in general, problems were properly identified, evaluated, and corrected. The team noted that your staff reviewed operating experience for applicability to station activities. Audits and self-assessments were performed at an appropriate level to identify most deficiencies. Based on the independent assessment of safety culture results, interviews conducted during the inspection, and review of the employee concerns program, freedom to raise nuclear safety concerns was demonstrated.
Based on the results of this inspection, no findings were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects
Docket No. 50-315; 50-316 License No. DPR-58; DPR-74
Enclosure:
Inspection Report 05000315/2011008; 05000316/2011008 w/Attachment: Supplemental Information
REGION III==
Docket No:
50-315; 50-316 License No:
05000315/2011008; 05000316/2011008 Licensee:
Indiana Michigan Power Company Facility:
D. C. Cook Nuclear Power Plant, Units 1 and 2 Location:
Bridgman, MI Dates:
May 2, 2011, through May 20, 2011 Inspectors:
J. Rutkowski, Project Engineer, Team Lead
P. LaFlamme, Resident Inspector
V. Meghani, Regional Inspector
M. Munir, Regional Inspector
Approved by:
Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000315/2011008; 05000316/2011008; 05/02/2011 - 05/20/2011; D. C. Cook Nuclear
Power Plant, Units 1 and 2; Routine Biennial Problem Identification and Resolution Inspection This inspection was performed by three NRC regional inspectors and one D.C. Cook Nuclear Power Plant resident inspector. No findings or violations of NRC requirements were identified during this inspection. 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.
On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at D. C. Cook Nuclear Power Plant was generally effective.
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. 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 most deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP.
Problem Identification and Resolution A.
No findings were identified.
NRC-Identified
and Self-Revealed Findings B.
No violations of significance were identified.
Licensee-Identified Violations
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 Inspection Procedure 71152.
(71152B)
.1 a.
Assessment of the Corrective Action Program Effectiveness The inspectors reviewed the licensees Corrective Action Program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.
Inspection Scope The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC PI&R inspection in August 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 assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. The inspectors reviewed Action Requests (ARs), which the licensee considered equivalent to condition reports, and General Tracking (GT) items generated as a result of facility personnels performance in daily plant activities. In addition, the inspectors reviewed a selection of completed investigations from the licensees various investigation methods, which included root cause, apparent cause, and common cause investigations.
The inspectors selected the Unit 1 and 2 high head injection charging systems to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs. A 5 year review on the high head injection charging systems was undertaken to assess the licensees efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of the Unit 1 AB and CD emergency diesel generator systems and spent fuel pool cooling. A review of the use of the station maintenance rule program to help identify equipment issues was also conducted.
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 whether 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.
b.
- (1) Assessment Based on the information reviewed, including initiation rates of ARs and GTs, and interviews, the inspectors concluded that the threshold for identifying issues and initiating ARs or GT items was appropriate and consistent with licensees procedural requirements. In addition, the inspectors noted that the licensee reviewed trends in equipment and human performance on a regular basis.
Effectiveness of Problem Identification The inspectors noted that the licensee generates approximately 9000 ARs per year with the majority of the identified items being of relatively low significance. The inspectors also identified that approximately an additional 6000 items per year were identified as GTs. The licensee stated that GTs were not formally tracked as part of the CAP. The inspectors did however consider some items identified as GTs as being part of the licensees overall PI&R processes and several GTs were reviewed as part of the inspection. Additionally the resident inspector staff stated that they had identified some GTs that would be more appropriately classified as ARs.
Observations Inspectors noted that the licensee included self-revealing issues under the coding of self-identified issues which appeared to be inconsistent with the guidance and definitions in the NRC Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports.
However, additional review indicated that the inconsistency was due to the difference in NRC and licensee definitions of self-revealing issues and did not affect the overall program effectiveness. The licensee uses the code Event Driven to identify the issues that fit the self-revealing definition in the IMC 0612. GT 2011-6078, Assess the Event Driven Definition Against NRC Definition, was written to initiate a review of the used definitions.
From review of documents and from interviews with a sample of plant staff, the inspectors determined that organizations and individuals identified and documented issues in accordance with licensee expectations and procedural requirements. The interviews identified that, in at least one contractor organization, personnel identifying issues did not themselves initiate documentation, but referred issues to supervision, who had issues documented by a person familiar with licensee requirements.
No findings were identified.
Findings
- (2) The inspectors reviewed the classification of ARs and GTs and determined that, in general, ARs and GTs were assigned appropriate prioritization and evaluation levels.
Appropriate prioritization and evaluation levels were assigned during screening committee meetings observed by the inspectors. Evaluations in apparent cause and root cause reports that were reviewed were adequate. The inspectors noted some minor weaknesses in evaluation and identification of corrective actions.
Effectiveness of Prioritization and Evaluation of Issues During review of AR 2011-1783, Damaged Main Steam Pipe Supports in ESW Pipe Tunnel, the inspectors noted that multiple design and installation errors contributed to the problem identified in the AR. However, the licensee evaluation and corrective actions did not identify or evaluate the human performance deficiencies. The licensee captured this concern in AR 2011-5968, Human Performance Issues Not Addressed in AR 2010-1783.
Observations The inspectors noted that the backlog of open ARs was approximately 600 with an average age of about 60 days. There were approximately 3800 open GTs with no calculation of age since GTs are not normally tracked by the licensee under the CAP.
The inspectors noted instances where the planned actions under GTs were rescheduled just before the original scheduled completion date. In a few instances the inspectors found multiple rescheduling of the same item. In review of AR 2010-3656, 1-ABD-B-3D Breaker Tripped Open When Pump Auto Started, the inspectors noted that the enhancement actions, which had original due dates of June 2010, had been extended three additional times and were currently planned to be completed by September 2011.
Upon further discussions with licensee staff, the inspectors determined that the enhancement actions were not characterized as conditions adverse to quality and therefore more flexibility for resolution was allowed per the licensees CAP. The inspectors did not identify any rescheduled items that significantly affected plant processes or equipment.
No findings were identified.
Findings
- (3) In general, the inspectors noted that the corrective actions addressed the cause of the identified problem and appeared to have been effective in the majority of samples reviewed. While the licensee identified about 1300 examples of recurrence of an issue or ineffective corrective action, the inspectors identified no additional recurrence of items. The inspectors noted that there were some inconsistencies in closing out corrective actions and that those closeouts were not in accordance with station expectations. Additionally the inspectors noted that to fully evaluate the effectiveness of corrective actions may require reviewing multiple ARs and potentially GTs and some work orders.
Effectiveness of Corrective Actions The inspectors reviewed the corrective actions associated with AR 2010-3656, 1-ABD-B-3D Breaker Tripped Open When Pump Auto Started, and noted that the effectiveness review for the issue was completed as required by PMP-7030-CAP-002, Condition Evaluation, Action and Closure. Specifically, step 9 of AR 2010-3656-1, stated that an effectiveness review was not required, which was contrary to procedural requirements. After additional review, the inspectors determined that this deficiency was identified by the licensee while preparing for the NRC inspection.
This condition was entered into the licensees CAP as AR 2011-4631, No Effectiveness Review for Significant Condition Adverse to Quality. However, AR 2011-4631 was not Observations incorporated into or referenced in AR 2010-3656, which made it difficult to properly track and evaluate actions taken in response to the original AR.
The inspectors also reviewed enhancement actions associated with AR 2010-3656 that had been added as separate general tracking actions, 2010- 4132 and 2010-4104, which in turn called for minor procedure enhancements. The inspectors concluded that this illustrated another instance of complexity in following and evaluating actions taken in response to conditions adverse to quality.
The inspectors walked down the Unit 1 and 2 east motor driven auxiliary feedwater systems, essential service water pipe tunnel, and Unit 1 AB and CD emergency diesel generator systems to review system status and to sample the use of tagging to identify system status. The inspectors noted that deficiency tags associated with AR 09071002, Essential Service Water Pipe Tunnel Sump Pump, and AR 08127033, Breaker Labeled Wrong Potential Human Performance Error Trap, were not removed following AR closure. Failure to remove tags following AR and work completion could under certain circumstances result in failure to identify new equipment deficiencies. This issue was entered into the licensees corrective action program as AR 2011-5979, Improper DT Tag Removal When Completing/Cancelling Work.
The inspectors identified instances where actions requesting or tracking specific tasks were closed prior to completion of the tasks. AR 2010-9232, Trend Evaluation Needed on Firedoors/Dampers, was initiated to perform a trend evaluation on fire doors and dampers. Action Request 2010-9232, Action 5, stated there was a need to identify a standard manufacturing company for door latch/crash bar assemblies and for closure assemblies. The action was closed to a tracking action AR 2010-9232-9, which in turn was closed without the action being completed. Similarly, AR 2010-9232-6, action to provide training on installation and maintenance, was closed after the training was set up but not completed. The inspectors also identified inappropriate closure of AR 00839907-05, Identification of Unknown Piping Near 12-FP-104, and AR 08326051, Investigate Unidentified Pipe. The items were created for tracking of a task to investigate and identify a buried pipe associated with a root cause evaluation performed for AR 838930838930 Ruptured Fire Header on the West Side of the Plant. Both the AR 00839907-05 and the AR 08326051 were closed to a work order 55332059, which was in a cancellation request state. The licensee issued AR 2011-5992, Actions Closed Without Performing Requested Actions, and AR 2011-5420, Improper Coding Work Order 55332059.
The inspectors reviewed the licensees on-line equipment work order numbers. The number of items classified as critical appeared consistent with industry norms.
Although the inspectors did not identify any specific issue of concern, the inspectors questioned the size and age of the overall backlog. The inspectors noted that there were about 2800 open on-line work order items. About 230 of those were classified as corrective with an average age of 423 days; about 2500 were classified as deficient with an average age of 800 days. There were about 19 work orders that were over 10 years old and about 325 that were over 5 years old. The inspectors noted that the licensee was in the process of reclassifying work orders under a recently implemented new classification scheme.
The inspectors also reviewed the open procedure change requests since procedure effectiveness might influence the effectiveness of corrective actions. The licensee had about 2250 open procedure enhancement requests with about 300 classified as requiring more than just enhancements to the procedures.
No findings were identified.
Findings
.2 a.
Assessment of the Use of Operating Experience The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing operating experience program procedures, attended meetings to observe the use of OE information, and completed evaluations of OE issues and events, and OE program Quick-Hit Self-Assessment. 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 and conducted by qualified personnel, 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 whether corrective actions, as a result of OE experience, were identified and effectively and timely implemented.
Inspection Scope b.
The inspectors determined that the overall performance of the operating experience program was adequate.
Assessment c.
No findings were identified.
Findings
.3 a.
Assessment of Self-Assessments and Audits The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental and program assessments and audits.
Inspection Scope b.
The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold level. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area.
Assessment c.
No findings were identified.
Findings
.4 a.
Assessment of Safety Conscious Work Environment The inspectors assessed the licensees safety conscious work environment through the reviews of the facilitys employee concern program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a Safety Culture Survey.
Inspection Scope The inspectors interviewed approximately 30 individuals from various departments to assess their willingness to raise nuclear safety issues. The individuals were selected to provide a distribution across the various departments at the site and included long-term contractors. The sample was of individuals predominantly at first-line supervision and below first-line supervision. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also addressed changes in the CAP and plant environment over the past two years. Items discussed included:
- knowledge and understanding of the CAP;
- effectiveness and efficiency of the CAP;
- willingness to use the CAP;
- managements support of the CAP;
- feedback on issues raised; and
- ease of input to the CAP database system.
b.
Interviews indicated that the licensee has an environment where people are free to raise issues without fear of retaliation. Documents provided to the inspectors regarding the 2011 safety culture assessment stated that D. C. Cook Nuclear Plant maintained a healthy safety culture. Based on results from NRC-conducted interviews and a review of the survey data, the inspectors did not identify any data that contradicted that conclusion but had questions on the survey response format and how several of the licensee-interview results were dispositioned by the licensees survey contractor.
Assessment All inspector-interviewed personnel indicated that station personnel would raise safety issues and were comfortable doing so. All interviewed individuals knew that, in addition to the CAP, they could raise issues to their management, to the Employee Concerns personnel, or to the NRC. None of the individuals interviewed indicated they had been retaliated against for raising issues nor were they aware of anyone who had been retaliated against. While most of the interviewees stated that they viewed the process for identifying and correcting issues as good, several interviewees indicated that they believed low-level issues could linger for long periods of time.
The licensees nuclear safety culture assessment (NSCA) was coordinated for the licensee by Utilities Service Alliance (USA). Allowable responses to written survey questions were: exceeds expectations, meets expectations, and does not meet expectations. As structured in the survey analysis both exceeds and meets expectations are counted as positive responses thus giving survey respondents the Observations choice of two positive and one negative response. NRC feedback to the Nuclear Energy Institute on the USA survey format is that the meets expectations response is a neutral response and should not be counted as either a positive or a negative response for survey interpretation.
The NSCA report only provided a general breakdown of survey responses associated with ten high-level principles used by the industry in safety culture assessment. While not providing the specific detail on the breakdown of responses to each survey question associated with elements (sub-principles) that make up each of the ten principles, the assessment report did provide graphs showing the inferred sub-principle breakdown of responses to questions asked during interviews with licensee personnel. The NSCA report stated that interview responses and survey data are both used to provide contextual cues in developing findings during an assessment. The NSCA report did list some negative observations, associated with sub-principles, which appeared to be consistent from the displayed interview responses shown in the assessment report. In reviewing the presented data the inspectors questioned why at least two of the interview sub-principles were not considered as negative response areas as they appeared to the inspectors as equal or more negative than some of the sub-principles listed as negative observations. The items were:
- 3F: effects of impending changes are anticipated and managed such that trust in the organization is maintained; and
- 6B: anomalies are recognized, thoroughly investigated, promptly mitigated, and periodically analyzed in the aggregate.
Licensee personnel, including some that participated in development of the final NSCA report, were not able to provide the inspectors the reasons for not including the above two items as negative observations other than re-stating that interview results were cognitively combined with survey results.
No findings were identified.
Findings
4OA6 Management Meetings
On May 20, 2011 the inspectors presented the inspection results to Mr. L. Weber 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.
Exit Meeting Summary
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
- M. Boznak, Work Control-Project Manager
Licensee
- K. Gossman, ESY/System Manager
- M. Horvath, Manager Employee Concerns
- M. Kennedy, Performance Improvement Specialist
- J. Labis, Employee Concerns Investigator
- R. Niedzielski, Senior Licensing Activity Coordinator
- R. Pickard, Engineering Program Manager
- T. Siefer, Engineer II
- M. Siewart, Maintenance
- J. Lennartz, Senior Resident Inspector
Nuclear Regulatory Commission
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None.
Opened
None.