IR 05000333/2006006

IR 05000333-06-006, on 07/10-28/2006, James A. FitzPatrick

ML062550144
Person / Time
Site:	FitzPatrick
Issue date:	09/11/2006
From:	Cobey E Reactor Projects Branch 2
To:	Peter Dietrich Entergy Nuclear Northeast
References
IR-06-006
Download: ML062550144 (16)

Text

ber 11, 2006

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO.

05000333/2006006

Dear Mr. Dietrich:

On July 28, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the James A. FitzPatrick Nuclear Power Plant. The enclosed inspection report documents the inspection results, which were discussed on July 28, 2006, with Mr. K. Mulligan and other members of your staff.

This inspection examined 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 license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The team concluded that Entergy staff properly identified, evaluated and corrected problems.

The team identified one finding of very low safety significance associated with the evaluation of an issue. This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as a non-cited violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the James A. FitzPatrick Nuclear Power Plant.

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 (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at http://www.nrc.gov/NRC/ADAMS/index. html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eugene W. Cobey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-333 License No. DPR-59 Enclosure: Inspection Report No. 05000333/2006006 w/Attachment: Supplemental Information cc w/encl:

G. Taylor, CEO, Entergy Operations, Inc.

M. Kansler, President, Entergy Nuclear Operations, Inc (ENO)

J. Herron, Sr, VP and Chief Operating Officer, (ENO)

C. Schwarz, VP, Operations Support (ENO)

K. Mulligan, General Manager, Plant Operations (ENO)

O. Limpias, VP, Engineering (ENO)

J. McCann, Director, Licensing (ENO)

C. Faison, Manager, Licensing (ENO)

M. Colomb, Director of Oversight (ENO)

D. Wallace, Director, Nuclear Safety Assurance (ENO)

J. Costedio, Manager, Regulatory Compliance (ENO)

T. McCullough, Assistant General Counsel (ENO)

P. Smith, President, New York State Energy Research and Development Authority P. Eddy, New York State Department of Public Service S. Lyman, Oswego County Administrator Supervisor, Town of Scriba C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law J. Sniezek, PWR SRC Consultant M. Lyster, PWR SRC Consultant S. Lousteau, Treasury Department, Entergy Services

SUMMARY OF FINDINGS

IR 05000333/2006006; 07/10/2006 - 07/28/2006; James A. FitzPatrick Nuclear Power Plant;

Problem Identification and Resolution.

The inspection was conducted by three region based inspectors and one resident inspector.

One Green non-cited violation was identified. The finding was evaluated using the significance determination process (SDP). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process. 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 3, dated July 2000.

Identification and Resolution of Problems The team identified that Entergy was effective at identifying problems and putting them into the corrective action program. Entergys effectiveness at problem identification was evidenced by the relatively few deficiencies identified by external organizations that had not been previously identified by Entergy. Entergy effectively used risk in prioritizing the extent to which individual problems would be evaluated and in establishing schedules for implementing corrective actions.

Entergy was effective in evaluating identified deficiencies and developing appropriate corrective actions. Corrective actions were implemented in a timely manner and were effective in correcting identified deficiencies. Entergy audits and self assessments were found to be effective. The team also determined that Entergy effectively used operating experience. In addition, the team determined that workers at the site felt free to enter problems in the corrective action program.

Cornerstone: Emergency Planning

Green: The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR), Part 50.65(a)(2), for Entergys failure to appropriately classify the January 2006 failure of the B train sample pump, 17P-4B, as a maintenance preventable functional failure. As a result, Entergy did not establish goals or monitor the performance of the stack high range radiation monitor, or demonstrate that monitoring was not required, in accordance with 10 CFR Part 50.65(a)(1).

The inspectors determined that this finding was more than minor because it was similar to Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues,

Example 7.b, in that, violations of 10 CFR Part 50.65(a)(2) necessarily involve degraded safety system performance or conditions. The finding was determined to be of very low safety significance (Green) because the redundant sample pump remained available and was promptly placed into service when B train sample pump, 17P-4B, failed.

ii

The inspectors determined that this finding had a cross-cutting aspect in the area of human performance because Entergy did not use a systematic decision-making process in determining the maintenance rule status of the plant stack high range effluent radiation monitoring system. (Section 4OA2.a)

B. License-Identified Violations None.

iii

REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R)(Biennial - 71152B)

.1 Assessment of the Corrective Action Program

a. Inspection Scope

The inspectors reviewed items selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Specifically, the inspectors selected 66 condition reports (CRs) for detailed review from approximately 20,000 that had been issued between August 2004 and July 2006. The inspectors reviewed the six audits and assessments of the corrective action program that were completed during the two year period. The team also reviewed the quarterly trend reports generated since August 2004 to determine if Entergy was effective at identifying developing performance problems in a timely manner.

The inspectors evaluated the CRs to determine Entergys threshold for identifying problems and entering them into the corrective action program. Also, Entergys efforts in establishing the scope of problems were evaluated by reviewing root cause assessments, apparent cause evaluations, extent of condition reviews, corrective action assignments and scheduling, work requests, engineering modification packages, self-assessment results, audits, system health reports, and results from surveillance tests and preventive maintenance tasks. For those CRs which had formal corrective actions to prevent recurrence (CAPRs), the inspectors reviewed the effectiveness evaluations performed by Entergy. The inspectors attended Entergys daily Operational Focus Meeting to understand the interface between the corrective action program and the work control process. The inspectors also conducted walkdowns of plant areas and systems to determine if degraded conditions existed which had not been entered into the corrective action program. The documents reviewed during the inspection are listed in the Attachment.

b. Assessment and Findings Identification of Issues The team determined that Entergy was effective at identifying problems and entering them into the corrective action program. This was evidenced by the few deficiencies coded in the Paperless Condition Reporting System (PCRS) as having been identified by external organizations, including the NRC, during the review period. The team did not identify any instances in which conditions adverse to quality were being dispositioned outside the corrective action program. The inspectors determined that station personnel had an appropriate knowledge of the corrective action program and entered problems into the system at an appropriate threshold. The inspectors also determined that Entergy was successful in identifying adverse trends through their quarterly trend reviews. Deficiencies were documented in CRs and appropriate corrective actions were developed. Adverse trends were identified, and CRs were generated to evaluate causes and determine appropriate actions to improve performance.

Prioritization and Evaluation of Issues The team determined that Entergy adequately evaluated and prioritized issues entered into the corrective action program. Operability determinations and reportability assessments were made promptly. The inspectors did not identify any instances where subsequent evaluation or analysis resulted in a different operability or reportability determination. The inspectors identified one non-cited violation, related to an inadequate evaluation of the failure of the B train stack high range effluent radiation monitoring system.

Introduction:

The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR), Part 50.65(a)(2), for Entergys failure to appropriately classify the January 2006 failure of the B train sample pump, 17P-4B, as a maintenance preventable functional failure. As a result, Entergy did not establish goals and monitor the performance of the system; or demonstrate that monitoring was not required, in accordance with 10 CFR Part 50.65(a)(1).

Description:

The plant stack normal and high range effluent radiation monitors share a two-train pumping system. According to Entergy procedure JAF-RPT-PRM-02286, Maintenance Rule Basis Document for System 017 Process Radiation Monitoring System, the high range effluent monitors are within the scope of the maintenance rule because their output is used to classify an Alert level emergency plan condition, which in turn, requires entry into Emergency Operating Procedure EOP-6, Radioactivity Release Control. The maintenance rule performance criteria for the high range effluent monitors is less than or equal to one functional failure per cycle, or two functional failures per subsystem, per cycle.

The B train sample pump, 17P-4B, failed on January 22 and April 8, 2006. On both occasions, the redundant sample pump was placed into service promptly to restore radiation monitor operability. The inspectors determined that Entergy incorrectly concluded that no maintenance preventable functional failure had occurred for the B train sample pump failure in January 2006 because they did not associate the B train sample pump with the high range effluent monitors. Entergy correctly evaluated the April 2006 B train sample pump failure as a maintenance preventable functional failure.

Due to the error in evaluating the January 2006 failure, Entergy did not recognize that the maintenance rule performance criteria had been exceeded. The inspectors also identified that Entergy did not perform preventive maintenance on the pumping system, as specified in ENN-DC-121, Maintenance Rule. As a result, the inspectors determined that Entergys failure to appropriately classify the January 2006 failure of the B train sample pump, 17P-4B, as a maintenance preventable functional failure, was a performance deficiency.

Analysis:

The inspectors determined that this issue was reasonably within Entergys ability to foresee and prevent. Traditional enforcement does not apply because there were no actual safety consequences or potential for impacting the NRCs regulatory function, and the finding was not the result of any willful violation of NRC requirements or Entergys procedures.

The inspectors determined that this finding was more than minor because it was similar to Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 7.b, in that, violations of 10 CFR Part 50.65(a)(2) necessarily involve degraded system performance. The inspectors evaluated the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, for emergency planning standard 10 CFR Part 50.47(b)(8), pertaining to the adequacy of facilities to support emergency response. The finding was determined to be of very low safety significance (Green) because the redundant sample pump remained available and was promptly placed into service when the B train sample pump, 17P-4B, failed.

The inspectors determined that this finding had a cross-cutting aspect in the area of human performance because Entergy did not use a systematic decision-making process in determining the maintenance rule status of the stack high range effluent radiation monitoring system.

Enforcement:

10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(2), requires, in part, that monitoring as specified in paragraph (a)(1) of this section is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function. Paragraph (a)(1) requires, in part, that a licensee shall monitor the performance or condition of structures, systems, or components within the scope of the monitoring program as defined in 10 CFR Part 50.65(b) against licensee-established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions.

Contrary to the above, in January 2006, Entergy failed to appropriately classify the failure of the B train sample pump, 17P-4B, as a maintenance preventable functional failure. As a result, Entergy failed to demonstrate that the performance or condition of the B train stack high range effluent radiation monitor was controlled through performance of appropriate preventive maintenance such that the monitor remained capable of performing its intended function. Specifically, after two B train sample pump failures on January 22 and April 8, 2006, which resulted in the maintenance rule performance criteria having been exceeded, Entergy failed to establish goals and monitor performance as required by 10 CFR Part 50.65(a)(1); or demonstrate that monitoring under 10 CFR Part 50.65(a)(1) was not required. Corrective actions included the development of a preventive maintenance program for the stack high range effluent radiation monitors which will include periodic replacement of the sample pumps and associated relief valves. Because this violation is of very low safety significance and has been entered into Entergys corrective action program (CR 2006-0212), this violation is being treated as an NCV, consistent with section VI.A.1 of the NRC Enforcement Policy: NCV 05000333/2006006-01, Failure to demonstrate that B train stack high range effluent radiation monitor sample pump performance was effectively controlled per 10 CFR Part 50.65(a)(2).

Effectiveness of Corrective Action The inspectors concluded that Entergys corrective actions for identified deficiencies were implemented in a timely and effective manner. Administrative controls were implemented to ensure that corrective actions were completed as scheduled. Reviews were performed to ensure that for significant conditions adverse to quality, corrective actions to prevent recurrence were implemented as intended. Entergy appropriately identified ineffective or improper closeout of corrective actions and initiated further actions to resolve the issues.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed Entergy procedure EN-OE-100, Operating Experience Program, Revision 2, and 40 CRs coded as operating experience reviews, to determine how operating experience was evaluated and how the resulting lessons learned were promulgated to the appropriate organizations.

b. Assessment and Findings The inspectors determined that Entergy was effective at evaluating and utilizing operating experience.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed self-assessments and audits of the corrective action program which had been performed since August 2004 to determine whether Entergy has been effective in identifying and resolving deficiencies. The team reviewed the results of Entergys 2006 safety culture survey, and discussed the results with senior plant managers.

b. Assessment and Findings The inspectors determined that Entergy was effective in identifying problems through audits and self-assessments. Entergy audits and assessments were of sufficient depth and identified issues similar to those that were self-revealing or raised during previous NRC inspections. Areas for improvement were also identified and entered into Entergys PCRS as Learning Organization items.

Entergy periodically performs safety culture surveys, identifies areas for improvement, and develops and implements actions to address each of these areas. The results of the 2006 Entergy safety culture survey revealed that FitzPatricks scores showed a declining trend since 2002 and were average when compared to the rest of the Entergy nuclear fleet. The inspection did not identify any results that were inconsistent with Entergys conclusions which were developed from the 2006 safety culture survey.

.4 Assessment of Safety Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors reviewed the Entergy safety culture survey results and discussed the results with site managers. The inspectors also reviewed the information in the quarterly trend reports on CR generation by organizational level and work group. The inspectors discussed and observed the use of the corrective action system by Entergy personnel during discussions with plant personnel.

b. Assessment and Findings The inspectors determined that site personnel were willing to raise issues and document them in the corrective action program. The team found no evidence of conditions which would inhibit the free flow of information relating to nuclear safety issues. Entergys quarterly trend reports indicate that personnel at all levels of the organization and in all site work groups are entering issues into the corrective action program, and that few anonymous CRs are being written. The team noted instances where site personnel were recognized by Entergy management for identifying issues and bringing them to their managements attention. This included a human performance stoplight at the plant entrance which highlighted issues identified by plant staff through good questioning attitudes.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On July 28, 2006, the inspectors presented the inspection results to Mr. K. Mulligan, and other members of the FitzPatrick plant staff, who acknowledged the results. All proprietary information reviewed by the team was returned to Entergy at the end of the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

K. Mulligan, Plant Manager

W. Rhaume, Manager, Corrective Actions and Assessments

D. Nacamuli, Corrective Actions Coordinator

D. Penfield, Operations Support Engineer

N. Chapman, Welding Supervisor

R. Johnson, Maintenance Corrective Action Coordinator

S. Scott, Project Engineer

R. Post, Reactor Engineer

S. Haskell, System Engineer

J. Cook, Program and Component Engineering Supervisor

S. Reed, In-Service Inspection Coordinator

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000333/2006006-01 NCV Failure to Demonstrate that B Train Stack High Range Effluent Radiation Monitor Sample Pump Performance was Effectively Controlled per 10 CFR 50.65(a)(2)