IR 05000333/2012008

IR 05000333/2012008; 02/26/12-03/16/12; James A. FitzPatrick Nuclear Power Plant; Biennial Baseline Inspection of Problem Identification and Resolution

ML12114A279
Person / Time
Site:	FitzPatrick
Issue date:	04/23/2012
From:	Mel Gray Reactor Projects Branch 2
To:	Michael Colomb Entergy Nuclear Northeast
References
IR-12-008
Download: ML12114A279 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ril 23, 2012

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2012008

Dear Mr. Colomb:

On March 16, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed report documents the inspection results, which were discussed 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 Commission=s rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspection team concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. FitzPatrick personnel identified problems and entered them into the Corrective Action Program at a low threshold.

FitzPatrick staff prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

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

In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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/

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

Enclosure:

Inspection Report 05000333/2012008 w/Attachment: Supplemental Information

REGION I==

Docket No.: 50-333 License No.: DPR-59 Report No.: 05000233/2012008 Licensee: Entergy Nuclear Northeast (Entergy)

Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, New York Dates: February 27 through March 16, 2012 Team Leader: David Kern, Senior Reactor Inspector, Division of Reactor Safety (DRS)

Inspectors: Anne DeFrancisco, Enforcement Specialist, Office of the Regional Administrator Niklas Floyd, Reactor Engineer, Division of Reactor Projects (DRP)

Beth Sienel, Resident Inspector, DRP Andrey Turilin, Project Engineer, DRP Approved by: Mel Gray, Chief Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000333/2012008; 2/26/12 - 3/16/12; James A. FitzPatrick Nuclear Power Plant; Biennial

Baseline Inspection of Problem Identification and Resolution.

This NRC team inspection was performed by four regional inspectors and one resident inspector. 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.

Identification and Resolution of Problems The inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. James A. FitzPatrick Nuclear Power Plant (FitzPatrick) personnel identified problems, entered them into the corrective action program (CAP) at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, station personnel appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent-of-condition, generic issues, and previous occurrences.

The inspectors also determined that Entergy personnel typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that, in general, Entergy adequately identified, reviewed, and applied relevant industry operating experience to FitzPatrick operations. In addition, based on those items selected for review, the inspectors determined that Entergys self-assessments and audits were self-critical and thorough. Station personnel effectively identified and elevated adverse performance trends for senior site management review through use of the Entergy Trending Process.

Based on interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify indications that site personnel were unwilling to raise safety issues nor did they identify conditions that could have had a negative impact on the sites safety conscious work environment.

No findings were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R)

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. Documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed Entergys procedures that describe the Corrective Action Program (CAP) at 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. 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.

To assess the effectiveness of the corrective action program, the team reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The team compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and Entergy procedure EN-LI-102, Corrective Action Process, Revision 17. Insights from the stations risk analyses were considered to focus inspection sample selection and plant walkdowns on risk-significant systems and components. Additionally, the inspectors attended multiple operational focus meetings, Condition Review Group (CRG) meetings, and Corrective Action Review Board (CARB)meetings to evaluate real-time prioritization and assignment of CRs. The inspectors reviewed a sample of CRs across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP) and selected items from the following functional areas:

engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs to ensure that Entergy personnel appropriately addressed problems identified in these functional areas.

(1) Effectiveness of Problem Identification The team selected issues 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, system health reports, operator workarounds, operability determinations, equipment problem lists, completed corrective and preventive maintenance work orders (WOs), completed surveillance test procedures, operator logs, periodic trend reports, and issues entered into the Employee Concerns Program (ECP).

Plant areas walked down included the emergency service water (ESW) and the direct current (DC) electrical distribution systems, the control building (including control room),screenwell, emergency diesel generators, warehouse, and the reactor building.

Additionally, the inspectors reviewed a sample of CRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Entergy staff entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of CRs issued since April 2010, approximately 6 months prior to the last NRC biennial Problem Identification and Resolution inspection. 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 reviewed to ensure they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Entergys completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergys timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected non-cited violations (NCVs) and findings to verify that Entergy personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Entergys actions related to ESW and DC electrical distribution system issues.

b.

Assessment

(1) Effectiveness of Problem Identification Station personnel initiated approximately 15,000 CRs between April 2010 and February 2012. Based on the selected sample reviews, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Entergy staff at FitzPatrick identified problems and entered them into the corrective action program at a low threshold. The team observed managers and supervisors at CRG meetings and CARB meetings appropriately questioning and challenging CRs to ensure issues were accurately documented, prioritized, and immediate corrective actions implemented if appropriate. The inspectors determined that Entergy personnel trended equipment and programmatic issues, and properly identified and documented problems in CRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. The inspectors did not identify any significant issues or concerns that had not been entered into the corrective action program for evaluation and resolution. In response to questions and minor equipment observations identified by the inspectors during plant walkdowns, Entergy personnel promptly initiated condition reports and/or took action to address the issues.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Entergy prioritized and evaluated issues commensurate with the safety significance of the identified problem. Condition Reports were screened for operability and reportability, categorized by significance, and assigned to the appropriate department for evaluation and resolution. The CR screening process considered human performance issues, equipment issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment. The team observed managers and supervisors at CRG meetings properly questioning and challenging CRs to ensure appropriate prioritization.

Based on the sample of CRs reviewed, the team determined the guidance provided by the Entergy CAP implementing procedures was sufficient to support 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 Entergys root cause analyses were generally thorough, and corrective and preventive actions addressed the identified causes. The identified causes were well supported. However, the team determined Entergys evaluation of the following issue was deficient:

Evaluation of Emergency Response Organization (ERO) Call-Out Drill Deficiencies Several CRs, including CR 2011-06634, documented and evaluated instances where duty section ERO staff did not successfully respond during backshift ERO call-out drills.

Entergy staff identified duty section ERO responder deficiencies in seven consecutive quarterly drills (April 2010 to December 2011). FitzPatrick ERO procedures require all qualified ERO staff to respond to call-out drills. The team concluded Entergys evaluation and corrective actions for associated equipment related deficiencies were timely and successful by December 2010. However, the team determined that associated human performance related deficiencies were not fully evaluated and corrected in a timely manner. Duty section ERO responder deficiencies, due to human performance issues, continued until broader corrective actions were implemented toward the end of 2011.

The team determined the untimely evaluation and correction of duty section ERO staff call-out drill response issue was a performance deficiency. However, Entergy successfully achieved ERO minimum staffing response within the 60 minutes required by the FitzPatrick Emergency Response Plan for each call-out drill because all ERO shifts, including the ERO duty section, respond to ERO call-outs. Additionally, corrective actions associated with ERO human performance deficiencies were fully implemented and successfully demonstrated during the March 2012 ERO backshift call-out drill.

Because Entergy maintained the ability to achieve ERO minimum staffing requirements during each drill and corrective actions were demonstrated to be effective in March 2012, the team determined the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

(3) 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 PI&R inspection were timely and effective.

Notwithstanding overall effective corrective actions, the team noted an issue for which initial corrective actions were not effective and deficient performance continued. The issue involved a large number (111) of personnel contamination events (PCEs) during the fall 2010 refueling outage (R19) (CR 2010-07326). Entergy identified the issue and initiated corrective action in a timely manner. However, an elevated rate of PCEs continued through the end of R19. Entergy subsequently implemented additional levels of corrective action which have been successful to date. The team discussed the issue with station management to assess whether Entergy understood why initial corrective actions were not effective. The issue involved periods of elevated contractor workforce activity, knowledge deficiencies, and human error. Entergy incorporated the issue into the FitzPatrick Quarterly Trend Report to elevate management visibility and station focus on continued effective performance in this area. The personnel contaminations issue was documented and evaluated in previous NRC inspection reports and does not represent a new performance deficiency or NRC finding.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team selected a sample of CRs associated with the review of industry operating experience (OE) to determine whether Entergy personnel appropriately evaluated the OE information for applicability to FitzPatrick and had taken appropriate actions, when warranted. The team also 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. Additionally, the team reviewed selected FitzPatrick operating history issues to determine whether lessons learned had been properly incorporated into station programs or activities. The team observed plant activities to determine if industry OE was considered during the performance of routine and infrequently performed activities.

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. Industry OE was evaluated for applicability in a timely manner. The team determined that, in general, OE was appropriately applied and lessons learned were typically communicated and incorporated into plant operations. However, the team identified the following observations where industry OE and/or FitzPatrick OE was not thoroughly incorporated into FitzPatrick plant operations to support equipment reliability:

Deficient Implementation of Mechanical Expansion Joint (EXJ) Preventive Maintenance (PM) Template and Associated Manufacturer Instructions The team reviewed Electric Power Research Institute (EPRI) Technical Report 1003189, Expansion Joint Maintenance Guide, October 2002, which was developed based on over 20 years of related industry OE, and reviewed the Entergy PM template and 17 work orders (WOs) for periodic replacement of ESW and normal service water (NSW)

EXJs. The WOs provided general instruction to remove the old EXJ, clean surfaces, install, and bolt the replacement EXJ in place. The team noted that contrary to the Entergy EXJ PM template, EPRI EXJ maintenance guidelines, and manufacturer instructions, the WOs did not contain instruction to perform measurement and installation checks of critical EXJ alignment parameters (i.e., EXJ elongation, compression, lateral alignment, angular alignment). Expansion joint installation outside of its design alignment tolerances can significantly shorten EXJ service life and thereby reduce system availability and reliability. The team discussed the issue with Entergy personnel and determined the EXJ PM template task content was not considered and implemented when developing ESW and NSW EXJ replacement maintenance work packages. Station personnel reviewed EN-DC-324, PM Program, Revision 7 and EN-DC-335, PM Basis Template, Revision 3 with the team and determined further evaluation was necessary to ensure PM templates were properly implemented in plant equipment PM WOs. The team also noted the Entergy EXJ PM template specified a 20-24 year replacement periodicity, which is almost double that specified in several vendor manuals. Entergy could not provide a basis for the replacement periodicity.

The team independently evaluated this issue for significance in accordance with IMC 0612, Appendices B and E. The team also performed plant walkdowns of 20 installed EXJs, reviewed EXJ inspection PM and station material history records, and interviewed FitzPatrick staff to assess the condition of installed ESW and NSW EXJs. The team identified no EXJ-related material deficiencies. Although Entergy did not verify EXJs were installed in accordance with critical design alignment parameters, the team determined the installed ESW and NSW EXJs currently appeared capable of performing their design functions, and therefore did not have a significant impact on plant operations. The team determined this issue is of minor significance, and, as a result, it is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Entergy initiated CR 2012-01474, CR 2012-01509, and CR HQN-2012-00345 to evaluate these issues and the associated extent-of-condition.

Deficient Use of Internal OE Associated with Main Condenser Tube Reliability The team conducted interviews and reviewed the main condenser material condition, engineering evaluations, and corrective actions associated with eight plant downpowers to plug leaking condenser tubes since January 2011. Entergy determined that typical flow induced tube wall thinning over the condensers operational life caused the tube leaks and that the condenser tubes were nearing their end of useful service life. The original condenser tubes were replaced in 1995 with identical brass material. The original condenser performed reliably for a 20 year period, which had included approximately 4 years of plant outages when the condenser was not in service.

Engineers expected the current condenser tubes to perform reliably for 20 years (i.e.,

until about 2015), similar to the previous condenser tubes. The team observed that Entergy did not properly consider FitzPatrick operating history, specifically the 4 years of outages, when projecting the expected condenser tube life. Consequently, Entergy did not properly plan and design for condenser tube replacement prior to tube leakage which has necessitated frequent downpowers for repair. Planned corrective actions include condenser tube sleeving during the Fall 2012 refueling outage and a complete replacement of all condenser tubes in the Fall 2014 refueling outage.

The team determined that not correctly assessing plant operating experience for main condenser tube replacement was a performance deficiency. The team independently evaluated this issue for significance in accordance with IMC 0612, Appendices B and E.

The evaluation took into consideration that: condenser tube leakage is a slowly developing phenomenon, automatic leakage monitoring equipment (i.e., condensate conductivity) is in place, and existing operating procedures provide instructions for operator response to condenser tube leaks. Additionally, the condenser remained capable of removing heat and did not adversely affect the Initiating Events, Mitigating Systems or Barrier Integrity objectives. The team determined the issue was of minor safety significance and, as a result, is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of Quality Assurance (QA) audits, including the most recent audit of the CAP, departmental self-assessments, a variety of self-assessments focused on various plant programs, and assessments performed by independent organizations. 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 NRC-identified observations made during the inspection.

Additionally, the team reviewed FitzPatrick implementation of EN-LI-121, Entergy Trending Process, Revision 11.

b. Assessment Station personnel consistently developed detailed audit and self-assessment plans. 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 CAP for evaluation. Corrective actions associated with the issues were implemented commensurate with their safety significance. The team determined that FitzPatrick personnel effectively used the Entergy Trending Process to identify several trends at a precursor level and focus management attention to address issues before they significantly challenged safety. Notwithstanding, the team observed that 5 of 27 trend presentations in the fourth quarter 2011 Trend Report were not updated to reflect current trend status. The team concluded that use of outdated information could adversely affect the resulting Senior Assessment Review Board (SARB) decisions. Entergy Staff entered this issue into the CAP (CR 2012-01471). Overall, the team concluded that FitzPatrick staff effectively identified and elevated trends to the SARB for timely resolution.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the team assessed whether issues exist that may represent challenges to the free flow of information, and whether underlying factors exist that would produce a reluctance to raise nuclear safety concerns at FitzPatrick.

Specifically, the team interviewed personnel to determine their willingness to raise safety concerns to their management, and/or the NRC. The team also reviewed EN-EC-100, Guidelines for Implementation of the Employee Concerns Program (ECP), Revision 5 and 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. The team reviewed selected Employee Concerns Program files from January 2009 to February 2012, including employee termination and retirement debriefs, to ensure that Entergy entered issues into the corrective action program when appropriate. In addition, the team reviewed actions taken by Entergy personnel to address recommendations from the most recent ECP self-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. The ECP Coordinator was knowledgeable of program implementation, participated in industry peer audits and ECP activities, and maintained ECP visibility at FitzPatrick. The team determined the issues employees entered into the ECP contained no new safety issues that were not already addressed through the CAP. 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.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On March 16, 2012, the team presented the inspection results to Mr. Michael Colomb, 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 INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

M. Colomb, Site Vice President

C. Adner, Manager, Operations

M. Annett, Mechanical Systems Engineering Supervisor

V. Bacanskas, Manager, Design Engineering

J. Barnes, Manager, Emergency Preparedness

J. Bouck, Manager, Planning Scheduling & Outage

A. Brais, Operating Experience Coordinator

K. Brazeau, Electrical Systems Engineering Supervisor

S. Breg, Manager, Projects

B. Brown, Radiation Protection Supervisor

C. Brown, Manager, Quality Assurance

B. Burnham, System Engineer

J. Cook, Equipment Reliability Engineer

K. Corbett, Corrosion Programs Engineer

R. Cushman, Security Shift Supervisor

B. Davis, Corrective Action and Assessments Specialist

R. Denbleyker, Employee Concerns Coordinator

D. Deretz, Corrective Action and Assessments Specialist

B. Dingman, Mechanical Planner

J. Festa, Training Superintendant

B. Finn, Director Nuclear Safety Assurance

K. Fox, Manager, Human Resources

M. Hawes, Licensing Specialist

W. Hall, Radiation Protection Technician

S. Hillestead, Radiation Protection Supervisor

T. Holden, Communications Specialist

D. Huwe, Quality Assurance Supervisor

H. Hunt, Manager, Corrective Action and Assessments

D. Johnson, Coordinator, Site Vice President Office

D. Kazyaka, Balance of Plant Systems Engineering Supervisor

A. King, RP Supervisor

D. Laing, Manager, Training

M. Lamardo, Electrical Maintenance Specialist

B. Landers, Chemistry Supervisor

D. Nacamuli, Senior Corrective Action and Assessments Specialist

M. Newshan, Operations Shift Manager

J. OFarrill, Senior Licensing Specialist

J. Pechacek, Manager, Licensing

J. Perry, Preventive Maintenance Program Owner

D. Poulin, Manager, Systems Engineering

L. Rayle, Chemistry Superintendant

T. Redfearn, Manager, Security

M. Reno, Manager, Maintenance

T. Selby, Preventive Maintenance Coordinator

A. Storm, System Engineer

P. Scanlan, Manager, Programs Engineering

B. Sullivan, General Manager, Plant Operations

G. Sullivan, Security Superintendent

R. Sullivan, Manager, Operations Support

M. Tufillaro, Radiation Protection Supervisor

D. Wallace, Director, Engineering

E. Wolf, Manager, Radiation Protection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None