IR 05000331/2011008
| ML111520430 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 06/01/2011 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
| To: | Costanzo C NextEra Energy Duane Arnold |
| References | |
| IR-11-008 | |
| Download: ML111520430 (27) | |
Text
une 1, 2011
SUBJECT:
DUANE ARNOLD ENERGY CENTER PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000331/2011008
Dear Mr. Costanzo:
On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at the Duane Arnold Energy Center.
The enclosed report documents the inspection results, which were discussed on April 29, 2011, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The inspection concluded that your staff was effective at identifying problems and incorporating them into the corrective action program. In general, issues were appropriately prioritized, evaluated, and corrected, audits and self-assessments were thorough and probing, and operating experience was appropriately screened and disseminated. Your staff was aware of the importance of having a strong safety-conscious work environment and expressed a willingness to raise safety issues.
However, there were several examples where standards were not being reinforced.
These examples were not new and had been previously identified by both the NRC and your Nuclear Oversight group. In the aggregate, these issues demonstrated a continued acceptance of program weaknesses or vulnerabilities.
No violations or findings were identified during this inspection. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-331 License No. DPR-49
Enclosure:
Inspection Report 05000331/2011008 w/Attachment: Supplemental Information
REGION III==
Docket No: 50-331 License No: DPR-49 Report No: 05000331/2011008 Licensee: NextEra Energy Duane Arnold, LLC Facility: Duane Arnold Energy Center Location: Palo, IA Dates: April 11 - 29, 2011 Inspectors: N. Shah, Project Engineer - Team Lead R. Murray, Resident InspectorDuane Arnold A. Dahbur, Senior Reactor Engineer C. Zoia, Operating Licensing Examiner Approved by: Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000331/2011008; (April 11 - 29, 2011), Duane Arnold Energy Center; Biennial Baseline
Inspection of the Identification and Resolution of Problems.
This team inspection was performed by three regional inspectors and the site resident inspector.
Based on the results of this inspection, there were no findings or violations identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. 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.
Identification and Resolution of Problems Overall, the Corrective Action Program (CAP) was appropriately identifying, evaluating, and correcting issues. Workers were generally encouraged to raise issues and felt comfortable doing so. Operating experience was recognized as valuable and was being well communicated.
The Nuclear Oversight (NOS) group was maintaining a good oversight role and self-assessments were generally good.
However, there were several examples where standards/expectations were not being reinforced. These examples were not new and had been previously identified by the NRC,
NOS and licensee oversight efforts. In the aggregate, these issues demonstrated a continued acceptance of program weaknesses or vulnerabilities.
Examples identified by the Team included a failure to consistently reinforce station expectations for Apparent Cause (ACE) and Operating Experience (OE) evaluations; a failure to ensure that Conditions Adverse to Quality (CAQs) were appropriately screened; and a failure to ensure that corrective actions were properly managed in the CAP.
The licensee had a strong safety culture and workers were comfortable with raising issues with station management. However, the inspectors noted that the licensees efforts to identify underlying human performance issues and potential safety culture concerns were not very good due to limitations in the process.
NRC-Identified
and Self-Revealed Findings None.
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
The activities documented in Sections
.1 through .4 constituted one biennial sample of
Problem Identification and Resolution (PI&R) as defined in Inspection Procedure (IP) 71152.
.1 Assessment of the Corrective Action Program (CAP) Effectiveness
a. Inspection Scope
The inspectors reviewed the licensees CAP implementing procedures and attended selected CAP program meetings to assess the implementation of the CAP by site personnel.
The inspectors reviewed risk and safety-significant issues in the licensees CAP since the last NRC PI&R inspection in April 2009. The items selected ensured an adequate review of issues across the 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. Additionally, the inspectors reviewed CAP items generated as a result of facility personnels' performance in daily plant activities. The inspectors also reviewed CAP items and a selection of completed investigations from the licensees various investigation methods, including root, apparent, and common cause evaluations.
The inspectors performed a more extensive review of the safety-related High Pressure Coolant Injection (HPCI) system. This review consisted of a five year search of related issues identified in the CAP and discussions with appropriate licensee staff to assess the licensees efforts in addressing identified concerns.
The inspectors attended meetings of the Issue Screening Team (IST) and Management Review Committee (MRC) to observe how issues were being screened and evaluated and to obtain insights into the licensees oversight of the CAP program.
During the reviews, the inspectors evaluated whether the licensees actions were in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B requirements.
Specifically, the inspectors evaluated if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues.
The inspectors also assessed whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also reviewed the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including Non-Cited Violations (NCVs).
b. Assessment
- (1) Effectiveness of Problem Identification Issues were generally being identified at a low threshold, evaluated appropriately, and corrected in the CAP. Workers were familiar with the CAP and felt comfortable raising concerns. This was evident by the large number of CAP items generated annually; which were reasonably distributed across the various departments. A shared, computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response. These processes included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.
The licensee allowed some items to be tracked outside of the CAP database due to the minor nature of the issues. These items included, but were not limited to, minor procedural changes, Routine Work Tracking items, and training program improvements.
The inspectors reviewed some of these items and verified that they were of low enough significance to not warrant inclusion in the CAP. The inspectors also noted that these items were routinely reviewed during MRC meetings.
Trending of issues had improved since the 2009 PI&R inspection. The inspectors noted an increased number of trends being identified and improved procedural guidance regarding when to issue a trend. A review of specific trend evaluations did not identify any concerns. However, the inspectors noted that the licensee still considered trending a weakness, due in part, to staff not applying the appropriate trend coding and to recent changes in the CAP software. This issue was documented as CAP item 342241.
The licensee had identified a negative trend in component mispositionings and was taking corrective action. However, the inspectors noted that not all potential mispositioning events were being identified as such in the CAP. For example:
o Common Cause Evaluation (CCE) 1628155 (2011 Operations Human Performance) identified an event where a vital area door was found unlocked; however, this issue was not counted as a mispositioning event.
o Mispositioning events where control rods were moved incorrectly and where locked valves were found unlocked or with the locking mechanism not installed, were specifically excluded from being identified as mispositioning events per Station Procedure 1410.15, Attachment 2.
The inspectors were concerned that by not properly identifying applicable issues as mispositioning events, the licensee would have a false indication of performance.
This issue was documented as CAP item 1646143.
In 2009, the licensee began assigning Nuclear Safety Culture Aspects to selected issues in order to identify potential adverse trends in human performance. While useful, the effort is of limited value as these Aspects were only assigned to NRC findings and not to licensee self-identified or near miss events. Given that NRC findings constituted only a small subset of the total issues in the CAP, this resulted in a low probability of identifying an adverse trend at a precursor stage. This issue was documented as CAP item 1646247.
While reviewing ACE 1918 Perform Aggregated Review of ECP 1871 Related CAPs, the inspectors noticed that a modification (ECP 1871) to replace 10 Motor Control Center (MCC) buckets also replaced the existing non-temperature compensated thermal overload relays with temperature-compensated relays having the same size as the existing heaters. The inspectors noted that the modification package failed to evaluate whether the new relays were adequate for the application. The inspectors also noticed that document number DGC-E112, Engineering Design Guide Thermal Overload Relay Application and Sizing, did not include steps for sizing temperature-compensated overload relays. The licensee subsequently verified that the relays were adequate for their applications. The failure to perform the necessary evaluation prior to replacing the relays was considered a minor violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, since the heaters were later determined to be adequate. This issue was documented as CAP item 1645100.
The inspectors identified that Operating Instruction (OI)-711, Pumphouse HVAC System, and Annunciator Response Procedure (ARP)-1C23C, Annunciator Response Procedure Panel 1C23C Main Plant HVAC, listed the incorrect room temperature (185 deg F vs 165 deg F) for operability of the emergency service water and residual heat removal service water pumps. The inspectors were concerned that if a loss of Pumphouse ventilation occurred, operators may incorrectly consider both pumps operable. A licensee review identified no past instances where Pumphouse temperature exceeded the operability limits or where operators had made an incorrect operability call.
Therefore, this was considered a minor violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedure, and Drawings. This issue was documented as CAP item 1643862.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors observed that the majority of issues identified were of low-level and were either closed to trend or at a level appropriate for a condition evaluation. Issues were being appropriately screened by both the IST and MRC and the inspectors had no concerns with those items assigned an ACE or root cause evaluation. There were no items in the operations, engineering, or maintenance backlogs that were risk-significant, individually or collectively. The inspectors also identified no issues during the review of the Operations Decision Making Instruction (ODMI) process.
Expectations for classifying items as either Conditions Adverse to Quality (CAQs) or Not Conditions Adverse to Quality (NCAQs) were not always being followed.
The inspectors found several examples where CAQs had been screened as NCAQs.
For example, the inspectors identified that an issue involving the HPCI minimum flow control valve (discussed below) had been misclassified as an NCAQ, instead of a CAQ.
This misclassification of issues was a recurring issue that had been previously identified during the 2009 PI&R inspection and subsequently, by the resident inspectors.
After the 2009 inspection, the licensee had proposed a change to the corporate procedure to remove the NCAQ designation. Although this change has not yet been implemented, the licensee has been implementing the CAP as if it has occurred.
This practice could send a mixed message to workers regarding procedural adherence and may result in some issues not being properly addressed due to confusion in the procedural requirements and actual practice. This issue was documented as CAP items 1640695 and 578709.
Most issues screened in the CAP were closed to a work request or to another CAP report. Generally, both the parent and daughter documents had the necessary verbiage to document the interrelationship. However, the inspectors identified some examples of inadequate cross-referencing. This issue was documented as CAP items 1645132, 1641114, and 1641427.
The inspectors noted that while Root Cause evaluations were of good quality, this was not always true of ACEs. There were several examples where it was difficult to discern how the evaluator had arrived at the stated conclusions either due to poor documentation or a limited evaluation. A similar issue was identified in the 2009 PI&R inspection and in a subsequent NOS audit report. In both cases, the cause was identified as a failure by licensee management to reinforce expectations for ACE quality.
Subsequently, the licensee changed the CAP to require that all ACEs be reviewed by the MRC. Previously, the MRC only reviewed a sampling of ACEs.
However, the inspectors identified that the MRC was not always doing a good job of reinforcing ACE quality as evidenced by the following examples:
o ACE 1977 identified potential process issues with the coordination of shipments due to the absence of qualified shipping personnel and/or the qualifications of shipping staff in training. These issues were not fully addressed in the ACE nor were corrective actions assigned. This discrepancy was not identified by the MRC during its review. During interviews with the current shipping coordinator, the inspectors noted that these issues may still exist.
o The inspectors observed that during a meeting on April 13, 2011, the MRC had identified several concerns with an ACE but failed to question why the ACE had received a passing score by the originating department. This was the second time this ACE had been reviewed by the MRC (it had been rejected the first time).
The inspectors identified other ACEs of concern which had received passing scores by the issuing department and had been reviewed by the MRC, but there was no evidence that the MRC had taken corrective action. This issue was documented as CAP items 1641115 and 1646241.
Findings No findings were identified.
- (3) Effectiveness of Corrective Actions Corrective actions were generally appropriate for the identified issues. Over the 2 year period encompassed by the inspection, the inspectors identified no significant examples where problems recurred.
The inspectors noted that corrective action due dates for some CAQs were often extended without having an adequate justification. This appeared to be due to a change in the CAP procedures (occurring after the 2009 PI&R inspection), which only required such justification for issues classified as either significance level 1 or 2 but not for those classified as significance level 3, even if the issue was a CAQ. Prior to the change, all corrective actions associated with CAQs required documented justification (including a risk evaluation) prior to extension.
One example was a CAQ associated with the HPCI minimum flow control valve.
In February 2010, the licensee identified oil intrusion into the motor actuator for this valve. The issue was classified as significance level 3, with the assigned corrective action being to replace the motor actuator and send the old one offsite for failure analysis. The inspectors noted that this action had been extended five times, with none of the justifications evaluating the risk from extending the due date. The inspectors also noted that the same issue had been identified with another HPCI valve back in 1999.
This previous issue had not been captured in the CAP and no action had been taken to identify the cause. For the recent issue, the current due date is August 2011, but this will likely be further extended due to a problem with the vendor assigned to complete the failure analysis. The end result is that a CAQ identified in 1999 and again in 2010 is still not corrected, as the cause of the oil intrusion has never been identified.
The failure to take corrective action to address this CAQ was considered a minor violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action. It was considered minor, because in both cases (1999 and 2010) the affected motor actuator was replaced. Additionally, the licensee has inspected all valve motor actuators on a three-year frequency and has not identified any other cases of oil intrusion.
The licensee documented the issue with due date extensions and with the failure to take corrective action to address the oil intrusion as CAP items 1641039, 1640695, and 1641653.
Findings No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed the licensees implementation of the facilitys OE program.
Specifically, the inspectors reviewed implementing OE program procedures, observed daily meetings for the use of OE information, and reviewed completed evaluations of OE issues and events. The intent was to determine if 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 if corrective actions, as a result of OE experience, were identified and implemented effectively and in a timely manner.
b. Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.
The inspectors noted that the licensee had made some improvements to the OE process since the 2009 PI&R inspection. For example, station procedures now required that OE be specifically evaluated as part of an ACE. However, the quality of these OE reviews continued to be a concern. Several examples were identified where ACEs did not evaluate whether the inappropriate use of OE was a precursor to the subject issue.
One example was ACE 597395, regarding several unplanned personnel contaminations after workers inappropriately entered the vessel upper head area. The ACE identified that a similar event had occurred in 2004, but did not evaluate whether corrective actions from that event should have prevented recurrence. The inspectors later determined that no corrective actions had been taken in 2004. The licensee documented this issue as CAP item 1646241.
Findings No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions through efforts from departmental assessments and audits.
b. Assessment The inspectors considered the quality of the NOS audits to be thorough and critical.
The department self-assessments were acceptable but were not of the same level of quality as the NOS audits. The inspectors observed that CAP items had been initiated for issues identified through the NOS audits and self-assessments.
Findings No findings were identified.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The inspectors assessed the licensees safety-conscious work environment (SCWE)through the reviews of the facilitys employee concerns program (ECP) implementing procedures, discussions with ECP coordinators, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results of licensee safety culture surveys.
The inspectors reviewed the following ECP case files (titles redacted): 10-74, 10-75, and 11-01R and CAP item 598538, Upper Management Questioning Attitude, dated December 1, 2010. These files and the CAP item involved potential cases of harassment and intimidation for raising safety issues.
b. Assessment The inspectors determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP process.
These results were similar with the findings of the licensees safety culture surveys.
Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.
The inspectors determined that the ECP process was being effectively implemented.
The inspectors noted that the licensee had appropriately investigated and taken constructive actions to address potential cases of harassment and intimidation for raising issues.
The inspectors noted that the licensee did not have an effective process for performing safety-culture surveys. Per procedure, the licensee was required to perform these surveys every three years. However, there was no guidance regarding how the surveys should be conducted, when the results should be communicated, how to interpret the results, or how to capture and resolve potential concerns. The most recent survey had been completed in July 2010, yet the results of the survey were not communicated until late March 2011. This prevented station management from taking timely action to resolve any potential concerns. Additionally, the survey results were in disagreement with actual performance. For example, according to the survey results, workers did not feel comfortable raising concerns (for fear of retaliation) and that the ECP program was inadequate. There was no clear indication whether this disconnect was due to the conduct of the survey or other issues. In addition, there was no requirement for the station to capture these conflicts in the CAP for resolution. This issue was documented as CAP item 1646273.
Findings No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
- On April 29, 2011, the inspectors presented the inspection results to Mr. Costanzo and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors returned to the licensee the results of the 2009 safety culture survey, which was the only item considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- C. Costanzo, Site Vice President
- R. Murrell, Licensing Engineer
- D. Brigl, Employee Concerns Investigator
- S. Catron, Licensing Manager
- D. Curtland, General Plant Manager
- P. Hansen, Performance Improvement Manager
- B. Kindred, Security Manager
- K. Kleinheinz, Engineering Director
- B. Porter, Radiation Protection/Chemistry Manager
- G. Pry, Operations Director
- J. Schwertfeger, Security Operations Supervisor
- R. Wheaton, Maintenance Director
- G. Young, NOS Manager
Nuclear Regulatory Commission
- K. Riemer, Chief, Branch 2, Division of Reactor Projects
- L. Haeg, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None.
Attachment