IR 05000333/2014007
| ML14133A051 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/12/2014 |
| From: | Arthur Burritt Reactor Projects Branch 2 |
| To: | Coyle L Entergy Nuclear Northeast |
| Burritt A | |
| References | |
| IR 14-007 | |
| Download: ML14133A051 (15) | |
Text
UNITED STATES May 12, 2014
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC SUPPLEMENTAL INSPECTION REPORT 05000333/2014007
Dear Mr. Coyle:
On January 21, 2013, your staff reported the unplanned power change performance indicator that crossed a threshold from green to white. Based on your report, the U.S. Nuclear Regulatory Commission (NRC) assigned a White performance indicator Action Matrix input to the Initiating Events cornerstone in the fourth quarter of 2012. In response to this Action Matrix input, the NRC informed you that a supplemental inspection under Inspection Procedure 95001,
"Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, would be required. On October 28, 2013, you informed the NRC that James A. FitzPatrick Nuclear Power Plant was ready for the supplemental inspection.
From January 20, 2014, to January 24, 2014, the NRC conducted the onsite portion of the supplemental inspection. On March 19, 2014, the NRC inspection team discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed inspection report. The NRC performed this supplemental inspection to determine if (1) the root and contributing causes for the risk-significant issues were understood, (2) the extent of condition and extent of cause for the identified issues were understood, and (3) your completed or planned corrective actions were sufficient to address and prevent repetition of the root and contributing causes.
The NRC determined that your staffs evaluation, in general, was thorough and that the planned corrective actions, which include replacement of the condenser tubes, will be sufficient to address the performance that led to the White performance indicator. The NRC also determined that the interim actions until the condenser can be replaced were reasonable; however, they have not been effective at reducing the number of unplanned power changes. Therefore, Entergys corrective actions to date have not been sufficient to meet the inspection objective to preclude repetition of the unplanned power changes and, as a result, this inspection will remain open until corrective actions to significantly reduce the unplanned power changes are implemented. The NRC will review Entergys implementation of additional corrective actions during a future inspection. The NRC also determined that there were some weaknesses in the root cause evaluation and corrective actions. Specifically, your staff identified the root cause to be a failure to include inner diameter condenser tube wear in any component or system monitoring plan. The inspectors determined that the root cause was narrowly focused and the licensee did not incorporate applicable operating experience from the 1995 condenser tube replacement into an appropriate system or program. Additionally, your staff did not adequately address a corrective action for the contributing cause of not identifying all appropriate internal operating experience in previous root causes. The NRC determined that these deficiencies were minor since your staffs additional extent of condition review in response to the inspectors root cause conclusion did not identify any new or missed issues, and the failure to assign a corrective action was an isolated example and did not represent a programmatic weakness. The NRC inspectors did not identify any findings or violations of more than minor significance.
In accordance with Title 10 of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records System component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No: 50-333 License No: DPR-59
Enclosure:
Inspection Report 05000333/2014007 w/Attachment: Supplementary Information
REGION I==
Docket No: 50-333 License No: DPR-59 Report No: 05000333/2014007 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, NY Dates: January 20, 2014, through January 24, 2014 (on site)
January 27 through March 17 (in-office review)
Inspectors: J. Krafty, Millstone Resident Inspector, Lead Inspector E. Torres, Calvert Cliffs Resident Inspector Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
IR 05000333/2014007; 01/20/2014 - 01/24/2014; James A. Fitzpatrick Nuclear Power Plant (FitzPatrick); Supplemental Inspection - Inspection Procedure (IP) 95001 Two resident inspectors from the Division of Reactor Projects, Region I, performed this inspection. No significant weaknesses or findings of more than minor significance were identified in this report. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Initiating Events
The NRC staff performed this supplemental inspection in accordance with IP 95001, Inspection for One or Two White Inputs in a Strategic Performance Area, to assess Entergys evaluation associated with the White performance indicator for unplanned power changes documented in the NRC Annual Assessment Letter, dated March 4, 2013. The inspectors concluded that Entergy was generally effective at identifying the problem, determining the root cause, extent of condition, extent of cause, and specifying corrective actions for the root and contributing causes.
Entergy appropriately identified and reported the unplanned power changes that were, except for one instance, caused by main condenser tube leaks. They also documented how long the issue existed, prior opportunities for identification, and plant specific risk consequences associated with the issue.
Entergy performed a comprehensive evaluation of the unplanned power changes. Entergy identified the primary root cause of the issue to be the failure to incorporate inner diameter condenser tube wear in any component or system monitoring plan. Entergy determined that other heat exchangers could be susceptible to tube wear and appropriately assessed the heat exchangers in the heat exchanger program to determine if they need to be monitored for inner diameter tube wall loss. Nonetheless, the inspectors determined that Entergys root cause was narrowly focused and that the root cause was the failure to incorporate applicable operating experience into an appropriate system or program. As a result, Entergy expanded their extent of condition review to adequately address the broader root cause.
Entergys corrective actions resulting from the root cause included establishing a monitoring and trending program for the main condenser and the East/West Electric Bay Coolers, revising the Corrective Action Review Board grading sheet for cause evaluations to better identify and address repetitive failures, and replacing the main condenser tubes with a more erosion resistant material during their next refueling outage. The inspectors identified that corrective actions for the contributing cause of not identifying all appropriate internal operating experience in the root cause had not been adequately addressed. Entergy entered a corrective action to address the issue through changes to the operating experience section of the root cause procedure. Entergy also implemented several interim actions to reduce the number of unplanned down powers as a result of main condenser tube leaks including sleeving the outlet ends of the condenser tubes. The NRC has concluded that the planned and implemented corrective actions will be sufficient to address the performance and underlying causes that led to the White performance indicator. The NRC also determined that the interim actions were reasonable; however, they have not been effective at reducing the number of unplanned power changes. Therefore, the corrective actions to date have not been sufficient to meet the inspection objective to preclude repetition of the unplanned power changes and, as a result, this inspection will remain open until corrective actions to significantly reduce the unplanned power changes are implemented. The inspectors will review Entergys implementation of additional corrective actions during a future inspection.
REPORT DETAILS
OTHER ACTIVITIES
4OA4 Supplemental Inspection
.1 Inspection Scope
The NRC staff performed this supplemental inspection in accordance with IP 95001 to assess Entergys evaluation of a White performance indicator, which affected the Initiating Events cornerstone in the Reactor Safety strategic performance area. The inspection objectives were to:
Provide assurance that the root and contributing causes of risk-significant issues were understood; Provide assurance that the extent of condition and extent of cause of risk-significant issues were identified; and Provide assurance that corrective actions for risk-significant issues were sufficient to address the root and contributing causes and to preclude repetition.
Entergy entered the Regulatory Response Column of the NRCs Action Matrix in the fourth quarter of 2012 as a result of a White performance indicator for unplanned power changes due primarily to main condenser tube leaks. The White performance indicator was documented in the NRC Annual Assessment Letter, dated March 4, 2013, because the number of Entergys unplanned power changes in the previous four quarters exceeded the Green/White threshold of six per 7000 critical hours.
Entergy informed the NRC staff on October 28, 2013, that they were ready for the supplemental inspection. In preparation for the inspection, Entergy performed root cause CR-JAF-2013-01240, Revision 1, to identify weaknesses that existed in the organization that were not identified in previous root causes that were performed as a result of the unplanned power changes. Entergys root cause also examined weaknesses in the safety culture components that contributed to the unplanned power changes.
The inspectors reviewed Entergys root cause evaluation (RCE) in addition to other evaluations conducted in support of the RCE. The inspectors reviewed corrective actions that were taken or planned to address the identified causes. The inspectors also held discussions with Entergy personnel to ensure that the root and contributing causes and the contribution of safety culture components were understood and corrective actions taken or planned were appropriate to address the causes and preclude repetition.
.2 Evaluation of the Inspection Requirements
2.01 Problem Identification a. As required by IP 95001, determine that the licensees evaluation of the issue documents who identified the issue (i.e., licensee-identified, self-revealing, or NRC-identified) and under what conditions the issue was identified.
Entergy identified that the performance indicator was exceeded on December 20, 2012, when an unplanned power change was required due to increased hotwell conductivity.
The inspectors verified that this information was documented in Entergys RCE.
b. As required by IP 95001, determine that the licensees evaluation of the issue documents how long the issue existed and prior opportunities for identification.
Entergys 2013 RCE documented that opportunities existed in RCEs CR-JAF-2007-03473 and CR-JAF-2009-00172 to identify previous FitzPatrick condenser operating experience that would have indicated that the condenser was nearing its end of life.
Additionally, Entergys 2013 RCE identified that, in 2010, an external organizations assessment identified that Entergy was not effectively addressing condenser issues.
The inspectors determined that Entergys evaluation was adequate with respect to identifying how long the issue existed and prior opportunities for identification.
c. As required by IP 95001, determine that the licensees evaluation documents the plant specific risk consequences, as applicable, and compliance concerns associated with the issue(s).
Entergys RCE documented that the risk consequences of condenser tube leaks were low. The condenser is not a safety-related component and is not considered risk significant by Entergys probabilistic risk assessment. Condenser tube leaks are readily identified by installed instrumentation and the affected waterbox can be isolated while keeping the plant on line at reduced power. The RCE also noted that condenser tube leaks, if severe, could result in chemistry and corrosion issues with the reactor coolant system and fuel cladding. Entergys reactor, feedwater, and condensate chemistry is routinely monitored and procedures are in place to identify and provide corrective actions for chemistry issues to protect the reactor and fuel. These procedures are consistent with Electric Power Research Institute BWRVIP-190, BWR Vessel and Internals Project BWR Water Chemistry Guidelines. The inspectors concluded that Entergy appropriately documented the risk consequences and compliance concerns with the issue.
d. Findings
No findings were identified.
2.02 Root Cause, Extent of Condition, and Extent of Cause Evaluation a. As required by IP 95001, determine that the licensee evaluated the issue using a systematic methodology to identify the root and contributing causes.
Entergy used the following systematic methods to complete RCE CR-JAF-2013-01240:
Barrier analysis Cause-effect charting Performance Improvement International Methodology (to evaluate organizational and performance issues)
The inspectors determined that Entergy evaluated the issue using appropriate systematic methodologies to identify the root and contributing causes.
b. As required by IP 95001, determine that the licensees RCE was conducted to a level of detail commensurate with the significance of the issue.
Consistent with EN-LI-118, Cause Evaluation Process, Entergy conducted an RCE that included a comprehensive timeline of the condenser tube leak events, causal factors, extent of condition and extent of cause, a safety culture evaluation, a safety significance evaluation, operating experience reviews, corrective actions, and an effectiveness review. The RCE documented that the root cause was the failure to include inner diameter main condenser tube wear in any component or system monitoring plan.
Entergy also determined that other heat exchangers needed to be evaluated in order to determine if they required monitoring for inner diameter wear. The significant contributing causes were that the corrective action process did not effectively identify all causes of condenser degradation, and that the 2007 and 2009 RCEs missed opportunities to identify the 1995 condenser re-tubing operating experience.
The inspectors concluded that Entergys stated root cause was narrowly focused and only captured part of the root cause. The inspectors determined that the root cause was the failure to incorporate applicable operating experience into an appropriate system or program. Specifically, the knowledge that the condenser tubes would be expected to last only fifteen years and that sleeving the outlets ends of the tubes could extend the useful life of the condenser had not been adequately captured in programs and processes such as capital planning, preventive maintenance, and system health reports.
The inspectors determined that the root cause for the condenser issues was inadequate and was a performance deficiency since, as a consequence of the narrow focus, the extent of condition review was limited to monitoring of heat exchanger tube wear rather than considering broader operating experience such as component service life. The inspectors concluded that the performance deficiency was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Specifically, the issue was minor since it was not indicative of a programmatic weakness in Entergys ability to perform adequate RCEs. Additionally, when Entergy expanded their extent of condition review in response to the inspectors conclusion, they did not identify any new or missed issues. Entergy entered this issue into their corrective action process as CR-JAF-2013-01240, corrective action 40. The extent of condition associated with this issue is discussed in Section 2.02.d below.
c. As required by IP 95001, determine that the licensees RCE included a consideration of prior occurrences of the issue and knowledge of operating experience.
Entergy reviewed operating experience from multiple sources including the Institute of Nuclear Power Operations, the Entergy fleet database, and the site corrective action process, as well as relevant NRC generic information and communication items.
Entergys RCE identified several internal and external operating experience items that were relevant to condenser tube leaks. Entergy used that information to inform their efforts in determining the root cause of the condenser tube leaks and developing corrective actions. The RCE also identified that RCE CR-JAF-2011-0170 and other earlier RCEs on condenser tube leaks did not adequately consider the operating experience from the 1995 condenser re-tubing. The corrective action for this issue is discussed in section 2.03.a. Based on Entergys evaluation and conclusion, the inspectors determined that Entergys most recent RCE included consideration of prior occurrences and knowledge of prior operating experience.
d. As required by IP 95001, determine that the licensees RCE addresses the extent of condition and extent of cause of the issue.
The inspectors concluded that, in general, Entergys RCE adequately addressed the extent of condition and extent of cause of the issue. Entergys evaluation considered the extent of condition associated with lack of monitoring wear of condenser tubes. Entergy determined that this was applicable to all the heat exchangers in the heat exchanger monitoring program and reviewed past monitoring of these heat exchangers to determine if they require inner diameter tube wear measurements. Entergy evaluated these heat exchangers based on tube material, fluid type and velocity, and whether the heat exchanger was in continuous service or in standby. Entergy concluded that only the East/West Electric Bay Coolers required inner diameter measurements and implemented a preventive maintenance program for these coolers. The inspectors reviewed Entergys evaluation and determined that their conclusions were reasonable.
However, as previously described in Section 2.02.b, to address the extent of condition associated with the broader root cause identified by the inspectors, Entergy wrote corrective action 40 to CR-JAF-2013-01240 and performed a review of major equipment replacements from 1985 through 2000 to determine if there were any lessons learned that were not incorporated into appropriate programs. Entergy determined that the feedwater heaters were the only additional equipment replacements that met the review criteria. The review determined that organizational learnings were incorporated into the new feedwater heater design and inspection requirements, and that adequate replacement plans were in place.
Entergys evaluation also considered the extent of cause associated with the corrective action process not identifying all the causes of condenser degradation. Entergy determined that this was applicable to RCEs related to equipment failures and a corrective action was developed to review these RCEs for the past five years to verify that age-related degraded conditions were properly identified. Entergys review of the 43 cause evaluations concluded that nine had age-related degradation. The inspectors verified that the respective cause evaluations had corrective actions in place for the nine age-related issues. The review also recommended a collective review of the causal evaluations on the high pressure coolant injection system. The inspectors reviewed the results of Entergys corrective action and determined that their review was adequate.
The inspectors noted that the extent of condition and extent of cause in RCE CR-JAF-2013-01240 did not provide the reasons for limiting the scope and did not determine the associated risk as required by EN-LI-118. The inspectors determined that not documenting scope limits and the associated risk consistent with procedure requirements was a performance deficiency. The inspectors concluded that the performance deficiency was of minor significance since they were able to confirm, through staff interviews, that Entergys scope of extent of condition and extent of cause reviews were appropriate and thereby did not result in any missed opportunities to identify problems. Therefore, this documentation issue is not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy entered this issue into their corrective action process as CR-JAF-2014-01181.
e. As required by IP 95001, determine that the licensees root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components as described in Inspection Manual Chapter (IMC) 0305.
Entergy identified weaknesses in the following two cross-cutting areas in the most recent RCE:
Human Performance, Decision Making Component Entergy identified that the decision to delay condenser tube replacement from 2012 to 2014 was based on the risk of implementing the project on an accelerated schedule.
However, they identified that this decision was made without a comprehensive cost benefit analysis, which would have evaluated the potential cost and plant impact of not re-tubing the condenser in 2012. Entergys corrective actions included developing a Kepner-Tregoe decision analysis process to review and provide detailed documentation of the risk of not implementing large projects in the future.
Problem Identification and Resolution, Corrective Action Program Component While reviewing older RCEs on condenser tube leaks, Entergy identified that previous root causes failed to identify and correct repeat condenser tube failures. Entergy also identified that they failed to put in place actions to monitor and track condenser service life after replacing the condenser in 1995. Entergys corrective action was to develop a grading sheet for RCEs to challenge previous corrective actions that did not resolve previous failures.
Overall, the inspectors determined that Entergys most recent RCE included proper consideration of whether a weakness in any safety culture component was a root cause or a significant contributing cause of the issue.
The inspectors also noted that in a previous root cause, RCE CR-JAF-2009-00172, the root and contributing causes identified weaknesses in the Human Performance, Work Practices and Continuous Learning Environment cross-cutting areas, but the safety culture evaluation section of the report did not identify any weaknesses. The inspectors determined that this issue was a performance deficiency of minor significance since it was a limited to a documentation problem and corrective actions had already been established to address the safety culture issues. Therefore, it is not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy entered this observation into their corrective action process as CR-JAF-2014-00405.
f. Findings
No findings were identified.
2.03 Corrective Actions a. As required by IP 95001, determine that
- (1) the licensee specified appropriate corrective actions for each root and/or contributing cause, or
- (2) an evaluation that states no actions are necessary is adequate.
To address the root cause of not including condenser tube inner diameter wear in a monitoring plan, Entergy developed a monitoring plan for the main condenser that includes measuring and trending tube wall thinning and replacing the tubes in the main condenser as necessary. To address the contributing causes, Entergy developed a grading sheet for cause evaluations to question previous corrective actions that did not prevent recurrence and developed a Kepner-Tregoe decision process to evaluate the risks and costs of not implementing large projects.
The inspectors determined that the contributing cause of not identifying all appropriate internal operating experience in previous root causes had not been adequately addressed through corrective actions. The inspectors determined that this issue was of minor significance because it was an isolated example and did not represent a programmatic weakness in assigning corrective actions. Therefore, it is not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy entered this issue into their corrective action process as CR-HQ-2014-00066 to address this by providing additional guidance in EN-LI-118 for determining the scope of the operating experience search.
Entergys planned corrective actions to address the age related wear of the main condenser tubes is to replace them with a more erosion resistant material during the next refueling outage. Entergy also implemented a number of interim actions to reduce the number of unplanned down powers as a result of main condenser tube leaks, including sleeving the outlet ends of the condenser tubes. The inspectors determined that the interim actions were reasonable; however, they have not been effective at reducing the number of unplanned power changes.
The inspectors concluded that Entergys planned and implemented corrective actions were appropriate and addressed the root and contributing causes. Nonetheless, while the interim corrective actions to reduce the number of unplanned downpowers were reasonable, they were not effective. As a result, the corrective actions to date are not sufficient to meet the inspection objective to preclude repetition of the unplanned down powers.
b. As required by IP 95001, determine that the licensee prioritized corrective actions with consideration of risk significance and regulatory compliance.
Entergys corrective actions to address the root and contributing causes were prioritized in accordance with procedure EN-LI-102, Corrective Action Process. In setting priority, Entergy considered plant risk and evaluated the condenser as a low risk component.
The inspectors determined that the majority of the corrective actions were completed and remaining corrective actions had appropriate due dates. The inspectors noted that Entergy considered replacing the tubes in the main condenser in their refueling outage in the fall of 2012. However, Entergy was concerned that the accelerated project would create concerns with project quality, vendor and material availability, and other potential undesirable outcomes related to design inadequacy. Entergy believed that sleeving the outlet ends of the condenser in the fall 2012 outage would be sufficient to limit unplanned power changes until the 2014 outage. The inspectors concluded that the basis for project delay was reasonable. Based on the guidance in EN-LI-102, the inspectors determined that the corrective actions were prioritized with consideration of the risk significance and regulatory compliance.
c. As required by IP 95001, determine that the licensee established a schedule for implementing and completing the corrective actions.
Entergy assigned due dates for corrective actions in accordance with procedure EN-LI-102s requirements for timeliness. Completion dates for corrective actions were established and documented in the RCE. The inspectors verified that corrective actions scheduled to be completed before the date of this inspection were completed and appropriately documented, and reviewed the status of other assigned corrective actions.
The inspectors determined that a schedule had been appropriately established for implementing and completing the corrective actions.
d. As required by IP 95001, determine that the licensee developed quantitative and/or qualitative measures of success for determining the effectiveness of the corrective actions to prevent recurrence.
As documented in RCE CR-JAF-2013-01240, Entergy established measures for determining the effectiveness of the corrective actions. These measures included measuring the inner diameter of the main condenser tubes in accordance with the condenser heat exchanger program during their refueling outages in 2016 and 2018, and verifying that tube wear is consistent with the program monitoring plan. The inspectors determined that quantitative and qualitative measures of success had been developed for determining the effectiveness of the corrective actions to preclude repetition.
e. As required by IP 95001, determine that the licensees planned or taken corrective actions adequately address a Notice of Violation that was the basis for the supplemental inspection, if applicable.
This item was not applicable since there are no underlying NRC requirements for the unplanned power change performance indicator. Additionally, the primary contributor to the unplanned power changes was age related wear of the main condenser tubes. The main condenser is not a safety-related component and therefore is not directly addressed by the Fitzpatrick license, technical specifications, or 10 CFR 50, Appendix B.
f. Findings
No findings were identified.
2.04 Evaluation of IMC 0305 Criteria for Treatment of Old Design Issues The inspectors determined this issue did not meet the IMC 0305 criteria for treatment as an old design issue.
4OA6 Inspection Debrief Meeting
On March 19, 2014, the inspectors presented the inspection results to Mr. Larry Coyle, Site Vice President, and other members of the FitzPatrick staff, who acknowledged the findings. The inspectors asked Entergy if any of the material examined during the inspection should be considered proprietary. Entergy did not identify any proprietary information.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- L. Coyle, Site Vice President
- C. Adner, Manager Regulatory Assurance
- D. Bittinger, Supervisor E-FIN
- B. Bock, Chemistry Specialist
- D. Deretz, Supervisor Code and Plant Programs
- W. Drews, Supervisor Reactor Engineering
- G. Duffy, Licensing Contractor
- S. Egnaczyk, PM and PdM Engineer
- D. Huwe, Quality Assurance
- L. Normandeau, Engineering Liaison
- M. Sassone, System Engineer
- D. Starczewski, Coordinator Equipment Reliability
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None