IR 05000333/2014009

IR 05000333-14-009; 04/14/2014 - 05/01/2014; James A. FitzPatrick Nuclear Power Plant, Biennial Baseline Inspection of Problem Identification and Resolution

ML14157A023
Person / Time
Site:	FitzPatrick
Issue date:	06/05/2014
From:	Arthur Burritt Reactor Projects Branch 2
To:	Coyle L Entergy Nuclear Northeast
Burritt A
References
IR 14-009
Download: ML14157A023 (18)

Text

une 5, 2014

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2014009

Dear Mr. Coyle:

On May 1, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed inspection report documents the inspection results, which were discussed on May 1, 2014, with Mr. Brian Sullivan, General Manager of Plant Operations, and other members of your staff.

The inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and 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 inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems and entered them into the corrective action program at a low threshold. Entergy prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate.

The inspectors determined that the self-assessments reviewed were generally thorough, critical, and effective in identifying issues and improvement opportunities. Finally, the team found no evidence of significant challenges to FitzPatricks safety conscious work environment. Based on the teams observations, FitzPatrick staff are willing to raise nuclear safety concerns through at least one of the several means available.

Based on the results of the inspection, the 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 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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management 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/

Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-333 License No. DPR-59

Enclosure:

Inspection Report 05000333/2014009 w/Attachment: Supplementary Information

REGION I==

Docket No. 50-333 License No. DPR-59 Report No. 05000333/2014009 Licensee: Entergy Nuclear Northeast (Entergy)

Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, NY Dates: April 14 through May 1, 2014 Team Leader: Carey Bickett, Senior Project Engineer Inspectors: Mark Draxton, Project Engineer Aaron Dugandzic, Project Engineer Beth Sienel, Resident Inspector, FitzPatrick Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

IR 05000333/2014009; 04/14/2014 - 05/01/2014; James A. FitzPatrick Nuclear Power Plant (FitzPatrick); Biennial Baseline Inspection of Problem Identification and Resolution.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Problem Identification and Resolution The inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. Entergy staff 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 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 staff 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 thorough.

Based on the 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 any indications that site personnel were unwilling to raise safety issues nor did they identify any 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

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

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Entergys corrective action program at FitzPatrick. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, and Entergy procedure EN-LI-102, Corrective Action Process. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended Condition Review Group, Condition Review Group Pre-Screening, Plant Health Committee, and Operations Focus meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and quality assurance programs.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, and periodic trend reports. The inspectors also completed field walkdowns of portions of various systems on site, including the residual heat removal service water, instrument air, primary containment atmosphere control and dilution, and emergency diesel generator systems. Additionally, the inspectors reviewed a sample of condition reports 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 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 condition reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in March 2012. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that 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 condition reports 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 condition reports associated with selected non-cited violations 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 feedwater pump issues.

b.

Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Entergy staff identified problems and entered them into the corrective action program at a low threshold. The inspectors observed supervisors at the various meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Entergy trended equipment and programmatic issues, and appropriately identified problems in condition reports. 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. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Entergy personnel promptly initiated condition reports and/or took immediate action to address the issues.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.

Entergy screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Entergys corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Entergy identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were generally timely and effective. However, the inspectors did observe some weaknesses in Entergys resolution of the following:

Improper Closure of a Corrective Action for a Procedure Revision Entergy wrote condition report CR-JAF-2013-4410 to evaluate the cause of high vibrations on the B reactor feedwater pump during power ascension on August 23, 2013. Entergy determined that the root cause of the issue was use of an inadequate maintenance procedure to reassemble the turbine to pump coupling following the Fall 2012 refueling outage. This resulted in the coupling disassembling during operation, causing the observed vibrations. Entergy issued a corrective action to preclude repetition to revise applicable sections of procedure MP-031.05, Reactor Feed Pump Turbine Coupling, to provide a more robust coupling. On March 6, 2014, station staff closed out the corrective action. The inspectors subsequently identified that all applicable steps of the procedure had not been revised.

EN-LI-102, Corrective Action Process, Section 5.9[4](d) requires that the corrective action assignerreviews each completed action and verifies that the required action is complete. This includes: ensuring that the response is adequate, answers all aspects of the assigned action, and the intent of the action is met. Contrary to this, Entergy closed the action in the corrective action program related to revising the procedure without completing the entire intended action. The inspectors determined this issue is of minor significance because although no longer being tracked by the corrective action program, a procedure revision to address applicable portions of the procedure was still in progress. Additionally, no maintenance had been performed on either of the feedwater pumps which would have required the use of this procedure, and related work orders were or have since been placed on hold. Entergy entered this issue into the corrective action process as condition report CR-JAF-2014-02159.

Failure to Implement a Corrective Action for Increased Frequency Low Voltage Testing On January 26, 2012, Entergy determined that a contactor associated with the east crescent area unit cooler fan motor failed the low voltage pick-up testing criteria per MP-056.01, AC Motor Control Center Maintenance and Subcomponent Replacement.

Entergy cleaned, lubricated, and reused the contactor, and replaced the contactor coil.

Post-maintenance testing of the contactor and new coil was satisfactory. Entergy documented this failure in condition report CR-JAF-2012-00584 and performed a high-tier apparent cause evaluation to assess the issue. Entergy staff determined that the apparent cause of the issue was higher contactor coil impedance which caused a lower current at a given voltage. This resulted in contactor pick-up at a voltage above the acceptance criteria. To test the effectiveness of the corrective actions already completed, Entergy developed an action to complete an increased frequency low voltage preventative maintenance test on a one year periodicity. Following three successful performances, the staff planned to return this preventative maintenance to its original seven year frequency. Entergy scheduled this work order and closed the associated corrective action.

Following review of condition report CR-JAF-2012-00584, inspectors questioned the status of the increased frequency preventative maintenance work order and discovered that it was inadvertently cancelled without completing the work. This is contrary to Entergy procedure EN-LI-102, Corrective Action Process, Section 5.8[6](e)(3) which states, before a work order which had a condition report or corrective action closed to it can be cancelled or closed with no work to be performed, the organization requesting the cancellation will present the condition report and work order to the Condition Review Group for discussion. By performing maintenance on the contactor, and replacing the contactor coil, Entergy completed actions to correct all of the probable causes of the failure, as identified in the apparent cause analysis. Additionally, the contactor and coil are currently within their seven year preventative maintenance frequency. The inspectors reviewed the basis for this seven year frequency and determined that it was reasonable. As such, the inspectors determined that this issue is minor. Entergy entered this issue into the corrective action process as condition report CR-JAF-2014-02016.

Failure to Properly Document Completion of Training The inspectors determined that station personnel were not always consistent in how they used corrective actions to track the completion of training. Entergy procedure EN-LI-102, Corrective Action Process, Section 5.9[4](b)(1) states, When training performance or modification to training material is identified as a corrective action in a condition report to address a cause or correct the identified condition, then the completion of the training or modification of training material must be documented in the condition report. Contrary to the above, Entergy closed two corrective actions associated with category B condition report evaluations to training evaluation action requests, and did not document the required corrective actions to track the completion of the training or modification of the training material. Specifically, condition report CR-JAF-2012-06868, corrective action eight, and condition report CR-JAF-2013-06344, corrective action nine, were both closed on December 11, 2012, and February 13, 2014, respectively, solely upon the initiation of a training evaluation action request, and did not have follow-on corrective actions to track the training completion. Closing a corrective action upon the initiation of a training evaluation action request and failing to have follow-on corrective actions to track the completion of the training leaves the station vulnerable by not ensuring that all necessary actions are completed.

In this case, the inspectors determined this issue was minor because Entergy completed the necessary training and modifications to the training material even though the actions were not tracked in the corrective action program. The station entered the issue into their corrective action process as condition report CR-JAF-2014-02009.

Inspectors independently evaluated these three observations in accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, and Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues. For the reasons discussed above, the inspectors determined that all of these issues were minor and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether Entergy appropriately evaluated the operating experience information for applicability to FitzPatrick and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Entergy staff adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that Entergy appropriately applied operating experience and communicated and incorporated lessons learned into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of various meetings at the station.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Entergy staff entered problems identified through these assessments into the corrective action program, when appropriate, and whether the staff initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Entergy assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Entergy personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Entergy completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at FitzPatrick. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees are aware of the program and its availability with regards to raising safety concerns. Additionally, the inspectors reviewed Employee Concerns Program files and the results of the most recent site safety culture assessment to ensure that Entergy entered issues into the corrective action program when appropriate.

b. Assessment During interviews, FitzPatrick staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors 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 corrective action program and the Employee Concerns Program. Based on the teams observations, FitzPatrick staff are willing to raise nuclear safety concerns through at least one of the several means available.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On May 1, 2014, the inspectors presented the inspection results to Mr. Brian Sullivan, General Manager of Plant Operations, and other members of the FitzPatrick staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Sullivan, General Manager of Plant Operations

M. Baker, Maintenance Rule Coordinator

A. Bratek, Containment Atmospheric Dilution System Engineer

S. Chubon, Senior Emergency Planner

M. Cook, Emergency Diesel Generator System Engineer

M. Cronk, Maintenance and Scheduling

J. Davis, Senior Corrective Action and Assessment Specialist

B. Dempsey, Residual Heat Removal Service Water System Engineer

R. Denbleyker, Employee Concerns Program Coordinator

M. Hawes, Regulatory Assurance Specialist

E. Hrbac, Project Manager for Projects

D. Huwe, Quality Assurance Auditor

S. Juravich, Engineering Fix-it-Now

A. King, Radiation Protection ALARA Supervisor

J. Krocke, Maintenance Coordinator/Scheduler

M. Lamardo, Electrical Maintenance

J. Lona, Electrical Outage Coordinator

M. Newshan, Assistant Operations Manager Support

R. Owen, Maintenance Specialist

R. Perry, Instrument Air System Engineer

D. Starczewski, Equipment Reliability Coordinator

S. Tharrett, Design Engineering Technical Specialist

P. Thingvoll, Chemistry Supervisor

NRC Personnel

E. Knutson, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

None