IR 05000333/2017008

Problem Identification and Resolution Inspection Report 05000333/2017008

ML17251A087
Person / Time
Site:	FitzPatrick
Issue date:	09/07/2017
From:	Arthur Burritt NRC/RGN-I/DRP/PB5
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Burritt A
References
IR 2017008
Download: ML17251A087 (16)

Text

UNITED STATES ber 7, 2017

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2017008

Dear Mr. Hanson:

On August 3, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-333 License No. DPR-59

Enclosure:

Inspection Report 05000333/2017008 w/ Attachment: Supplementary Information

REGION I==

Docket No. 50-333 License No. DPR-59 Report No. 05000333/2017008 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, NY Dates: July 17 - August 3, 2017 Team Leader: E. Burket, Reactor Inspector Inspectors: K. Kolaczyk, Senior Resident Inspector M. Patel, Reactor Inspector A. Bolger, Reactor Engineer Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000333/2017008; 07/17/2017 - 08/03/2017; 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 6.

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

Exelon 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 Exelon typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that Exelon 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 Exelons self-assessments and audits were thorough.

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 any indications that site personnel were unwilling to raise safety issues.

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 the corrective action program at FitzPatrick. Since the last NRC biennial problem identification and resolution inspection completed in May 2014, FitzPatricks management transitioned from Entergy Nuclear Northeast (Entergy) to Exelon. The transition, which occurred on March 31, 2017, resulted in the review of program effectiveness under two separate sets of program procedures and program processes. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: (1)problem identification,

(2) prioritization and evaluation of issues, and

(3) 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) Part 50, Appendix B, Criterion XVI, Corrective Action; Exelon procedure PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 5; and Entergy procedure EN-LI-102, Corrective Action Program, Revision 27.

For each of these areas, the inspectors considered risk insights from FitzPatricks risk analysis and reviewed Entergy condition reports (CRs) and Exelon issue reports (IRs)selected across the seven cornerstones of safety in the NRC's Reactor Oversight Process. Additionally, the inspectors attended multiple Station Ownership Committee and Management Review Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, physical security, emergency preparedness, radiation protection, chemistry, nuclear oversight, and the corrective action program.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed a sample of completed corrective and preventive maintenance work orders, completed surveillance tests, operator logs, and periodic trend reports. The inspectors completed field walkdowns of various systems, including the emergency diesel generators, the radioactive waste building, the control room, emergency service water, residual heat removal service water, and the east and west electric bays. Additionally, the inspectors reviewed a sample of CRs and IRs 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 Exelon 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 and IRs since the last NRC biennial problem identification and resolution inspection completed in May 2014. The inspectors also reviewed CRs and IRs that were assigned lower levels of significance and 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 evaluated equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Exelons completed corrective actions through documentation review, interviews, and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs and IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs and IRs associated with previous non-cited violations (NCVs) and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the review to five years to evaluate Exelons actions related to the emergency service water system and electric bay unit coolers.

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 Exelon identified problems and entered them into the corrective action program at a low threshold. The inspectors observed supervisors at Station Ownership Committee and Management Review Committee meetings appropriately questioning and challenging IRs to ensure clarification and proper classification of the issues. Based on the samples reviewed, the inspectors determined that, overall, Exelon appropriately trended equipment and programmatic issues, and identified problems in IRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. The 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 the inspectors observations of minor issues during the course of the inspection, Exelon personnel promptly initiated IRs and/or took immediate action to address the issues.

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

Exelon screened IRs for operability and reportability, categorized the IRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR 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 IRs reviewed, the inspectors noted that the guidance provided by Exelons corrective action program implementing procedures enabled consistency in the categorization of issues. Operability and reportability determinations were 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, Exelon identified actions to prevent recurrence. The inspectors reviewed a selected sample of NRC NCVs and findings since the last problem identification and resolution inspection and concluded that Exelons corrective actions were timely and effective. The inspectors noted the following observations associated with Exelons closure of corrective actions to resolve a condition adverse to quality that were determined to be minor in accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening:

Incomplete Closure Documentation of a Corrective Action to Address an Adverse Condition The inspectors reviewed CR-JAF-2016-01784, which was initiated in FitzPatricks corrective action program in May 2016 to document an NRC-identified condition associated with solid radioactive waste accumulating on the floor of the filter sludge tank room. The issue was dispositioned as an NCV of Green significance in NRC Integrated Inspection Report 05000333/2016002, dated August 12, 2016, because Entergy did not conduct operations to minimize the introduction of residual radioactivity into the site. To address the adverse condition, Entergy developed a corrective action to clean the resin off the floor, which was assigned as [corrective action] CA #3 and was being tracked under work order 382561, task 3. However, the inspectors reviewed work order 382561 and found that task 3 had a status of canceled. The inspectors verified completion of the corrective action through interviews with personnel involved in the clean-up of the resin. Additionally, Exelon personnel entered the locked high radiation area while the inspection team was onsite to confirm the resin was cleaned off the floor. The inspectors noted that EN-LI-102, Corrective Action Program, Section 5.6[4], step f.

stated, documentation needed to provide objective evidence that the action was completed should be attached to the CA or should be verified to exist in a quality controlled records location or database and be fully referenced to facilitate future retrieval. The lack of objective evidence to demonstrate completion of corrective actions could have had the potential to lead to a failure to ensure actions are taken to address deficiencies in a timely manner commensurate with the safety significance of the issue. The inspectors determined the lack of objective evidence that the action was completed was a performance deficiency. In this case, although actions were unconfirmed in the CAP, the actions were taken in a timely manner as confirmed by the inspectors; therefore, this performance deficiency was minor. Exelon documented this issue in their corrective action program as IR 4033022.

Procedural Non-compliance Regarding Documenting an NRC-issued Non-cited Violation EN-LI-123, NRC Inspection Support, Section 5.5, states, in part, that upon receipt of an NRC inspection report, the licensee will perform a review to confirm that each NRC violation has been entered into the CAP and that the condition description field matches the inspection report description. The inspectors reviewed the description of NCV 05000333/2016002-02, Failure to Conduct Operations to Minimize the Introduction of Residual Radioactivity to the Site, and compared it to the condition description field of CR-JAF-2016-01784 to determine whether the condition adverse to quality was adequately captured in Entergys corrective action program. The inspectors noted that contrary to EN-LI-123, Entergy did not initiate a new CR with a condition description field that matched the inspection report description. As a result, the assigned corrective actions in the condition report (2016-01784) did not have a clear connection to the description of the NCV. The inspectors concluded that not ensuring the description of the violation is included in the CAP could have potentially led to incorrectly assigning or incorrectly implementing corrective actions due to the lack of correspondence with the underlying performance issue. The inspectors noted that during the Regulatory Assurance closure review of the corrective actions that the licensee stated that the CR response was not adequate and did not consist of actions to characterize and evaluate the adverse condition identified by the NRC NCV. However, although this deficiency was addressed by the licensee, additional information was not added to the CR to characterize and evaluate the adverse condition to ensure it was correctly captured in the CAP. In this case, although the description was not accurately included in the CAP, the corrective actions taken were appropriate and therefore, this issue is minor. Exelon entered this minor performance deficiency into the corrective action program as IR 40338914.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of CRs and IRs associated with review of industry operating experience to determine whether Exelon 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 Exelon adequately considered the underlying problems associated with the issues for resolution via their corrective action program.

b. Assessment The inspectors determined that Exelon appropriately considered industry operating experience information for applicability and used the information to prevent, identify and correct similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also noted that industry operating experience was routinely discussed and considered during the conduct of station meetings and pre-job briefs.

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 Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against the NRC observations and conclusions developed by the inspectors during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon 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 also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.

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 these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On August 3, 2017, the inspectors presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the Exelon 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

J. Pacher, Site Vice President

T. Peter, Plant Manager

A. Bratek, Senior Engineer

P. Casey, System Engineer

C. Clancy, Organizational Effectiveness Manager

W. Davis, Corrective Action Program Manager

W. Drews, Regulatory Assurance Manager

K. Habayeb, ECCS Branch Manager

M. Hawes, Regulatory Assurance Specialist

S. Hillestad, Radiation Protection Technical Support Manager

C. Krassowski, Simulator Specialist

K. Meyer, System Engineer

H. Morehouse, Senior Operations CAP Coordinator

M. Needles, Discipline Planner Supervisor

D. Nichols, Operating Experience Coordinator

J. Pechacek, Shift Manager

T. Redfearn, Manager Site Security

R. Simons, Employee Concerns Program Coordinator

A. Smith, Operations Staff Scheduler

C. Smolinski, Manager Operations Support

G. Stefl, Senior Engineering Manager

G. Sullivan, Assistant Security Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

None