IR 05000333/2010007

IR 05000333-10-007; on 11/15/2010-12/3/2010; James A. Fitzpatrick Nuclear Power Plant Biennial Baseline Inspection of Problem Identification and Resolution

ML110120413
Person / Time
Site:	FitzPatrick
Issue date:	01/12/2011
From:	Mel Gray Reactor Projects Branch 2
To:	Bronson K Entergy Nuclear Northeast
References
IR-10-007
Download: ML110120413 (22)

Text

UNITED STATES N UCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2010007

Dear Mr.

On December 3, 2O1O,the U.S. Nuclear Regulatory Commission (NRC) completed an report inspection at your James A, FitzPatrick Nuclear Power Plant (FitzPatrick).^The enclosed 3,2010, with you and documents the inspection results, which were discussed on December other members of Your staff.

relate to This inspection was an examination of activities conducted under your license as they with the Commission's rules and the identification and resolution of problems, and compliance regulations and the conditions of your operating license. Within these areas, the inspection of involved examination of selected procedures and representative records, observations activities, and interviews with personnel'

was Based on the samples selected for review, the inspection team concluded that Entergy generally etfective in identifying, evaluating and resolving problems' In most instances, Fitzpatr* personnel identifled-problems it a low threshold and entered them into the operability and Corrective Action eiogiam. Fitzpatrick staff screened issues appropriately for problems'

reportability, and prioritized issues commensurate with the safety significance of the previous Causal anilyses appropriately considered extent of condition, generic issues, and in a occurrences. Gorrective actions addressed the identified causes and were implemented timely manner.

Based on the results of this inspection, no findings were identified.

K. Bronson 2 ln 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 the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at htto://www.nrc.qov/readino-rm/adams.html (the Public Electronic Reading Room).

Sincerely, l4'/-V"Y-Mel Gray, Cniet/

Projects Branch 2 Division of Reactor Projects Docket No.: 50-333 License No.: DPR-59

Enclosure:

Inspection Report 05000333/2010007 w/Attachment: Supplemental Information

REGION I Docket No.: 50-333 License No.: DPR-59 Report No.: 05000244t2010007 Licensee: Entergy Nuclear Northeast (Entergy)

Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, New York Dates: November 15 through December 3, 2010 Team Leader: Neil Perry, Senior Project Engineer, Division of Reactor Projects (DRP)

Inspectors: Javier Brand, Reactor Inspector, Division of Reactor Safety (DRS)

Sherlyn lbarrola, Reactor Inspector, DRS Sam McCarver, Project Engineer, DRP Ludwig Kern, Reactor Engineer, DRP Approved by: Mel Gray, Chief Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

f R 0500033312010007i 1111512010

- 121312010; James A. FitzPatrick Nuclear Power Plant;

Biennial Baseline Inspection of Problem ldentification and Resolution.

This team inspection was performed by five NRC regional inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, December 2006.

ldentification and Resolution of Problems The team concluded that Entergy personnel were generally effective in identifying, evaluating, and resolving problems. In most instances, FitPatrick personnel identified problems at a low threshold and entered them into the Corrective Action Program (CAP). The team determined that FitzPatrick staff screened issues appropriately for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. The team determined that corrective actions addressed the identified causes and were implemented in a timely manner.

Entergy's audits and self-assessments reviewed by the team were thorough and probing.

Additionally, the team concluded that Entergy personnel, in general, adequately identified, reviewed, and applied relevant industry operating experience (OE) to FitzPatrick. Based on interviews, observations of plant activities, and reviews of the CAP and the Employee Concerns Program (ECP), the team did not identify concerns with site personnel's willingness to raise safety issues nor did the team identify conditions that indicated a negative impact on the site's safety conscious work environment.

No findings were identified.

REPORT DETAILS

4OA2 Problem ldentification and Resolution (Pl&R)

(71 1528)

.1 Assessment of the Corrective Action Proqram (CAP) Effectiveness

a. Inspection Scope

The team reviewed Entergy's procedures that describe the CAP at the James A.

FitzPatrick Nuclear Power Plant (FitzPatrick). Entergy personnel identified problems by initiating condition reports (CRs)for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, and other significant issues.

Condition reports were subsequently screened for operability and reportability, categorized by significance level (A, most significant, through D, least significant), and assigned to personnel for evaluation and resolution or trending.

The team evaluated the process for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the team interviewed plant staff and management to determine their understanding of, and involvement with, the CAP.

The team reviewed CRs selected across the seven cornerstones of safety in the NRC's Reactor Oversight Process (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The team selected items from functional areas that included chemistry, emergency preparedness, engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure that Entergy personnel appropriately addressed problems identified in these functional areas. The team selected a risk-informed sample of CRs that had been issued since the last NRC Pl&R inspection conducted in September 2008. Insights from the station's risk analyses were considered to focus the sample selection and plant walkdowns on risk-significant systems and components.

The corrective action review was expanded to five years for the emergency diesel generators (EDGs) and the switchgear room heating, ventilation, and air conditioning (HVAC).

The team selected items from various processes at FitzPatrick to verify that they were appropriately considered for entry into the CAP. Specifically, the team reviewed a sample of engineering evaluations, operator workarounds, operability determinations, system health reports, equipment problem lists, work orders (WOs), and issues entered into the Employee Concerns Program (ECP). Plant areas walked down included the control building (including control room), screenwell, EDGs, and reactor building, The team reviewed CRs to assess whether Entergy personnel adequately evaluated and prioritized identified issues. The CRs reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. A sample of CRs that were assigned lower levels of significance which did not include formal cause evaluations were also reviewed by the team to ensure they were appropriately classified. The team's review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The team assessed whether the evaluations identified likely causes for the issues and appropriate corrective actions to address the identified causes. As part of this review, the team interviewed various station personnel to fully understand details within the evaluations, and the proposed and completed corrective actions. The team observed operations focus meetings and condition review group (CRG) meetings in which FitzPatrick personnel reviewed new CRs for prioritization and assignment.

Further, the team reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected CRs to verify these specific reviews adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems.

The team's review of CRs also focused on the associated corrective actions in order to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The team reviewed FitzPatrick's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. Lastly, the team reviewed CRs associated with NRC non-cited violations (NCVs) and findings since the last Pl&R inspection to determine whether FitzPatrick personnel properly evaluated and resolved the issues The team compared FitzPatrick's performance to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Entergy procedure EN-Ll-102, "Corrective Action Process." Documents revieWed during this inspection are listed in the Attachment to this report.

Assessment Effectiveness of Problem ldentification Based on the selected samples reviewed, plant walkdowns, and interviews of site personnel, the team determined that FitzPatrick personnel generally identified problems at a low threshold and entered them into the CAP. For the issues reviewed, the team noted that problems or concerns had been appropriately documented in sufficient detail to understand the issues. The team observed managers and supervisors at CRG meetings appropriately questioning and challenging CRs to ensure clarification of the issues. The team determined that Entergy personnel trended equipment and programmatic issues, and CR descriptions appropriately included references to repeat occurrences of issues. The team concluded that personnel were identifying trends at low levels. The team did not identify significant issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. Notwithstanding, the team identified some problems during plant walkdowns not identified by Entergy staff.

The issues were determined to be minor. In response to these issues identified by the team, Entergy personnel promptly initiated CRs and/or took immediate action to address the issue. Examples of instances where Entergy personnel had not identified issues include:

The inspectors identified two degraded Appendix R floor penetration fire seals. The fire seals had cracks and separation or shrinkage between the opening and the seal material (silicone foam). The fire seals (1FH334803 and 1FH334804) located between the'B' EDG switchgear room and the east cable tunnel had cracks that exceeded the acceptance criteria of 1-112 inch depth specified in MST-076.11, "Fire Barrier Penetration Functional Integrity Surveillance Test," Revision 18. FitzPatrick personnel immediately declared the seals nonfunctional and established hourly fire rounds for the affected areas. These two seals were repaired under work orders WO-257384 and 257385 and the seals were returned to fullfunctionality. ln addition, an Apparent Cause Evaluation was initiated per CR 2010-07935.

Engineers determined there was at least 9 inches of the foam fire seal installed and therefore functionality was not affected. These seals were last inspected by FitzPatrick in January 2008 and January 2002 and found acceptable.

The team determined this issue was minor, because, upon evaluation, there was sufficient seal penetration material (9 inches of the foam seal was installed) to perform its required 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire protection function.

The inspectors identified equipment in safety-related areas of the plant where Entergy staff did not use the proper restraints designated in AP-17.02, "Housekeeping and Cleanliness Control," for equipment in these safety-related areas. Specifically, the inspectors identified four carts in the control room that were restrained by a loose chain which was inadequate to prevent them from rolling into the adjacent instrument cabinets. Two portable gas cylinder carts, classified as medium weight equipment in AP-17

.02 , were not sufficiently restrained to prevent

them from tipping into the adjacent Reactor Protection System (RPS) instrument cabinets and were not located a minimum of four feet from the cabinets as required in AP-17.02. Two carts in the safety-related relay room adjacent to the control room were not restrained in any manner to prevent them from rolling into safety-related cabinets. A ladder in the 'D' EDG room was also found not properly secured.

Entergy personnel concluded that all cabinets which the loose carts could have impacted were constructed such that they had sufficient strength to prevent any damage to the equipment contained inside the cabinets. The inspectors determined these issues were minor because they could not reasonably conclude that the unrestrained equipment in the safety-related areas would have challenged the ability of safety-related equipment to perform its safety function. Additionally, no significant programmatic concerns were identified associated with the issue that, if uncorrected, could lead to worse conditions. Entergy has taken corrective action to provide adequate restraints for each piece of equipment.

.

The inspectors identified a potential seismic concern associated with the EDGs'fuel oil lines and air start lines. Specifically, the inspectors identified% inch, 1 inch and 2 inch nominal diameter piping in direct contact with % inch thick metal floor diamond deck plates as the pipes extend through the floor. The deck plates varied in size and were recessed in the floor trench, flush with the floor surface. Additionally, the diamond plates which are used to cover trenches in the EDG rooms were installed inconsistently, in that some plates were partially secured to the floor but many were not. FitzPatrick personnel initiated CR 2010-7906 to perform extent of condition walkdowns and inspections, and to evaluate the clearance conditions between the plates and the piping.

The engineering evaluation determined this condition would not have prevented the EDGs or associated piping and components from performing their intended safety function because the maximum (peak) seismic accelerations for the EDG building during a design basis earthquake would be minor due to the low seismic accelerations and the ability of the piping to withstand an impact from the plate.

Fitzpatrick personnel initiated WOs to cut the diamond deck plates around the pipes to create at least alzinch clearance. In addition, where practical, Fitzpatrick plans to secure the deck plates to the supporting frame within the floor trench.

The inspectors concluded that these issues were minor because the conditions did not impact operability of the EDGs or any of the associated support systems or components. No significant programmatic concerns were identified associated with the issue that could lead to worse conditions if uncorrected.

Effectiveness of Prioritization and Evaluation of lssues The team determined that, in general, Entergy personnel appropriately prioritized and evaluated issues commensurate with their safety significance. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The CR screening process considered human performance issues, equipment issues, radiological safety concerns, repetitiveness and adverse trends. The team observed managers and supervisors at CRG meetings appropriately questioning and challenging CRs to ensure appropriate prioritization.

CRs were categorized for evaluation and resolution commensurate with the significance of the issues. Based on the sample of CRs reviewed, the guidance provided by the Entergy implementing procedures appeared sufficient to ensure consistency in categorization of the issues. Operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusions.

Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. During this inspection, the team noted that Entergy's root cause analyses were generally thorough, and corrective and preventive actions addressed the identified causes. Additionally, the identified causes were well supported.

However, there was one instance of less than adequate evaluation:

.

The inspectors reviewed CR 2008-03534 and its associated corrective actions related to the maintenance department. A lack of procedural guidance for core spray pump to motor alignment acceptance criteria was identified in the CR. The inspectors identified that no corrective action was created to assess the need to update the procedure with acceptance criteria for alignment values. CR 2010-08189 was generated to document the concern. The inspectors determined the issue to be minor because subsequent evaluation determined the actual core spray pump to motor alignment was acceptable.

Effectiveness of Corrective Actions The team concluded that corrective actions for identified deficiencies were timely and adequately implemented. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. The team concluded that corrective actions to address NRC NCVs and findings since the last Pl&R inspection were, in general, timely and effective. There was, however, one example where corrective actions were not implemented:

.

The inspectors evaluated corrective actions taken in response to NCV 2008006-01, Inadequate Procedure Guidance to Address Spurious Failures of the RCIC and LPCI Systems, which identified that procedure AOP-28, "Operation During Plant Fires," does not identify that the 'A' residual heat removal (RHR) pump is susceptible to fire-induced spurious operation due to the fire damaging the pump start logic circuitry. As such, the AOP did not provide guidance for operators to take action to preclude operating the pump beyond the 10 minute recommended runtime on minimum flow. Corrective actions in CR 2008-01597 included adding a precaution to the procedure regarding the runtime restriction for the RHR pump while operating on minimum flow. However, operations personnel concluded that although the procedure was changed to identify that the 'A' RHR pump may automatically start spuriously during a fire, the procedure had not been changed to alert the operators regarding limiting runtime for the RHR pump on minimum flow. FitzPatrick personnel entered this issue into the CAP. Subsequent analysis determined that the RHR pumps may be run in a minimum flow configuration for up to two hours in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The inspectors determined this issue to be minor because this was a minor procedural error that had no impact on safety equipment and caused no safety consequences.

c. Findinqs No findings were identified.

.2 Assessment of the Use of Operatinq Experience

a. Inspection Scope

The team selected a sample of CRs associated with the review of industry operating experience (OE) to confirm that Entergy personnel appropriately evaluated the OE information for applicability to FitzPatrick and had taken appropriate actions, when warranted. The team reviewed CR evaluations of OE documents associated with a sample of NRC Generic Letters and Information Notices to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their CAP. The team also observed plant activities to determine if industry OE was considered during the performance of routine activities. A list of the documents reviewed is included in the Attachment to this report.

b, Assessment The team determined that Entergy personnel appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The team determined that OE was appropriately applied and lessons learned were generally communicated and incorporated into plant operations.

Findinqs No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. lnspection Scope The team reviewed a sample of Quality Assurance (QA) audits, including a review of several of the findings from the most recent audit of the CAP, and a variety of self-assessments focused on various plant programs. These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRO-identified observations made during the inspection. A list of documents reviewed is included in the Attachment to this report.

b. Assessment The team concluded that QA audits and self-assessments were critical, thorough, and effective in identifying issues. The team observed that these audits and self-assessments were completed by personnel knowledgeable in the subject areas and were completed to a sufficient depth to identify issues that were then entered into the I

CAP for evaluation, Corrective actions associated with the issues were implemented commensurate with their safety significance.

Findinos No findings were identified.

.4 Assessment of Safetv Conscious Work Environment

a. lnspection Scope During interviews with station personnel, the team assessed whether issues exist that may represent challenges to the free flow of information, and to determine whether underlying factors exist that would produce a reluctance to raise nuclear safety concerns atFitzPatrick. Specifically, the team interviewed personnel to determine their willingness to raise safety concerns to their management and/or the NRC. The team also interviewed the station ECP coordinator to determine what actions were implemented to ensure employees were aware of the program and its availability with regard to raising concerns. ln addition, inspectors reviewed corrective actions taken by Entergy personnel to address licensee-identified safety culture focus areas identified in both a 2009 station-specific and Entergy fleet-wide nuclear safety culture assessment.

b. Assessment During interviews, plant staff expressed a willingness to use the CAP to identify plant issues and deficiencies, and stated that they were willing to raise safety issues. The team noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and ECP. Based on these limited interviews, the team concluded that there was no evidence of an unacceptable safety conscious work environment (SCWE) and no significant challenges to the free flow of information.

With regard to the corrective actions taken to address the safety culture results from assessments performed by Entergy staff in 2009, the inspectors determined that Entergy's corrective actions were prioritized consistent with the potential safety significance of the issues, and were of sufficient scope and breath to address licensee identified focus areas. For example, in response to an indication that some station personnel may either not be comfortable initiating CRs or have a complete understanding of the types of issues that should be identified in a CR, training was provided to all station personnel on the importance of initiating CRs and how to use the CR system. As a result, there has been a significant increase in the average number of CRs written monthly and issues are being identified at a lower threshold which allows corrective actions to be initiated. Other actions that have been taken include development and execution of a communications plan to improve station personnel awareness and access to Entergy policies regarding nuclear safety culture. This also includes discussions of those policies during new employee orientation and periodic staff briefings focusing on the need to stay in process, and stopping and reporting to supervision if a procedure or work order cannot be performed as written. These actions have resulted in an increased level of awareness of Entergy policies by station personnel regarding safety culture, the role of the individual in safety culture, and the various avenues available for raising issues.

c. Findinos No findings were identified.

40A6 Meetinqs. lncludinq Exit On December 3, 2010, the team presented the inspection results to Mr. Kevin Bronson, Site Vice President, and to other members of the FitzPatrick staff. The team verified that no proprietary information was documented in the report.

ATTACHMENT: SUPPLEMENTAL I NFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

K. Bronson, Site Vice President

C. Adner, Manager, Operations

J. Barnes, Manager, Training and Development

A. Brais, Operating Experience Coordinator

K. Brazeau, Maintenance Rule Coordinator '

C. Brown, Manager, Quality Assurance

D. Burch, Design Engineering

B. Burnham, Engineering

R. Casella, Structural Engineer

P. Cullinan, Manager, Emergency Preparedness

R. Denbleyker, Employee Concerns Coordinator

M. Dooley, Supervisor, System Engineering

E. Dorman, Senior Licensing Manager

P. Farsaci, Operations

B. Finn, Director Nuclear Safety Assurance

M. Hawes, Licensing Specialist

H. Hunt, Manager, Corrective Actions and Assessment

D. Johnson, Manager, System Engineering

D. Koelbel, Fire Protection System Engineer

J. LaPlante, Manager, Security Operations

A. Mahammed, Supervisor, Mechanical Civil Design

D. Nacamuli, Senior Corrective Action and Assessments Specialist

C. Nye, Coordinator, Maintenance

J. Pechacek, Licensing Manager

M. Reno, Manager, Maintenance

D. Ruddy, Engineering

J. Solowski, Radiation Protection Supervisor

D. Stokes, Fire Protection Engineer

B. Sullivan, General Manager, Plant Operations

M. Woodby, Director, Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None