IR 05000341/2013007

IR 05000341-13-007; 11/04/2013 - 11/22/2013; Fermi Power Plant, Unit 2; Routine Biennial Problem Identification and Resolution Inspection

ML13347B320
Person / Time
Site:	Fermi
Issue date:	12/13/2013
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Plona J Detroit Edison, Co
References
IR-13-007
Download: ML13347B320 (27)

Text

ber 13, 2013

SUBJECT:

FERMI POWER PLANT, UNIT 2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000341/2013007

Dear Mr. Plona:

On November 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Fermi Power Plant, Unit 2.

The NRC inspection team discussed the results of this inspection with Mr. T. Conner and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.

Based on the inspection sample, the inspection team determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution.

These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available.

No findings were identified during this inspection.

M. Piona -2-In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 (PARS) component of the 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/

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket No. 50-341 License No. NPF-43

Enclosure:

Inspection Report 05000341/2013007 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-341 License No: NPF-43 Report No: 05000341/2013007 Licensee: Detroit Edison Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: November 4 - November 22, 2013 Team Lead: R. Morris, Senior Operations Examiner Inspectors: K. Carrington, Acting Resident Inspector R. Lerch, Project Engineer, RIII J. Rutkowski, Project Engineer, RIII Approved by: Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000341/2013007; 11/04/2013 - 11/22/2013; Fermi Power Plant, Unit 2;

Routine Biennial Problem Identification and Resolution Inspection.

This inspection was performed by three NRC regional inspectors and the Fermi 2 acting resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

Problem Identification and Resolution On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Fermi 2 was generally good. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP.

NRC-Identified

and Self-Revealed Findings No items of significance were identified.

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

problem identification and resolution as defined in Inspection Procedure 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspector reviewed the licensees Corrective Action Program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC Problem Identification and Resolution (PI&R) inspection in September 2011. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed issue reports generated as a result of facility personnels performance in daily plant activities. The inspectors also reviewed CAP items and a selection of completed investigations from the licensees various investigation methods, including root cause evaluations (RCEs), apparent cause evaluations (ACEs), and self-assessments.

The inspectors selected two high risk systems, the standby feedwater system and the reactor recirculation system, to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs.

A 5-year review on the reactor recirculation system was also undertaken to assess the licensee staffs efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdown of both systems.

During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys corrective action program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including non-cited violations.

Specific documents reviewed are listed in the Attachment.

b. Assessment

(1) Effectiveness of Problem Identification The inspectors concluded that issues were being identified at a low threshold, evaluated appropriately, and corrected in the CAP, and that workers were familiar with the CAP and felt comfortable raising concerns. This was evident by the large number of CAP items generated annually, which were reasonably distributed across the various departments. A shared, computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response.

These processes included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.

The inspectors concluded that the station was generally effective at trending low level issues to prevent larger issues from developing. A review of specific trend evaluations did not identify any concerns.

Observations The inspectors reviewed the licensees Performance Indicators (PIs) during the inspection. The self-identification rate compared to the outside identification rate was significantly lower during mid-year 2013. The licensee had recognized the trend and was addressing the issue through the CAP with training and group discussions. The trend improved during the last part of 2013 (as shown in the PI data) and the inspectors noted that management was sensitive to the issue.

In the review of Condition Assessment Resolution Document (CARD) generation rates, the team noted a decline. A 15-percent decline was projected in the rate of CARDs generated for 2013 from 2012. A decrease in the number of CARDs generated was also shown for most plant organizations to various degrees. The licensee did not have an explanation for the decrease but the inspectors did not identify any issues with the trend impacting the overall effectiveness of the program.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that overall performance in the prioritization and evaluation of issues was effective. In particular, the inspectors observed that the majority of issues identified were at a low level and were either closed to a trend or at a level appropriate for a condition evaluation. Issues were being appropriately screened by both the Station Oversight and Management Review Committees and the inspectors had no concerns with those items assigned an ACE, RCE, or common cause evaluation. There were no items identified by the inspectors in the operations, engineering, or maintenance backlogs that were risk-significant, either individually or collectively. The inspectors reviewed the licensees work order backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.

Observations The inspectors reviewed the performance metric data associated with corrective maintenance work orders or those work orders that represented a level of deficiency of a plant component that had failed and no longer conformed to or could perform its design function.

The inspectors noted that the number of corrective maintenance work orders associated with or requiring work on critical components has remained almost steady from the previous year, with 0 in October 2012 and 3 in September 2013.

The inspectors noted that the number of open corrective maintenance work orders associated with or requiring corrective maintenance on noncritical components has declined from the previous year with 43 in October 2012 and 29 in September of 2013.

The inspectors also noted that the number of open corrective maintenance work orders associated with or requiring corrective maintenance on critical and noncritical components that if not corrected would have very low consequence or impact on the plant has declined from the previous year with 292 in October 2012 and 253 in September 2013.

Based on these numbers, the inspectors noted that the licensee appeared to be effectively managing its work order backlog associated with performing corrective maintenance on those critical and noncritical components that had failed or would fail such that they could no longer perform their intended function, including those components whose failure would be of very low consequence.

The inspectors noted that while the licensee appeared to be adequately managing its work order backlog, the number of open work orders associated with plant components with potential or actual deficiencies that did not threaten the components design function or performance criteria had increased from the previous year.

Specifically, the number of open work orders requiring maintenance to be performed on critical components with potential or actual deficiencies remained mostly steady from the previous year with 58 in October 2012 and 58 in September 2013. However, the number of open work orders requiring maintenance to be performed on noncritical components with actual or potential deficiencies increased from 127 in October 2012 to 248 in September 2013. The number of open work orders for components classified as run-to-failure or critical and noncritical components with actual or potential deficiencies of very low consequence if left uncorrected decreased from 1410 in October 2012 to 1312 in September 2013. In combining the number of deficient noncritical and critical work orders, the licensee exceeded its performance threshold of 300. The licensee previously identified this gap and initiated CARD 13-27042 to capture the fact that the total on-line deficient work order back log increased from the previous year to 306, exceeding the licensees performance metric of 300.

The licensees work order back log appears to be adequately managed and work orders of higher priority or that pose the most risk or vulnerability to the plant were being appropriately worked. The inspectors review noted the licensees backlog contained at least 526 low priority work orders, and although they do not appear to pose any risk to the plant, the inspectors also observed that there are a number of low priority work orders over 5 to 10 years old. The inspectors commented to the licensee on the need to evaluate the potential impact of such low level priority work orders. The licensee entered this observation into its corrective action program as CARD 13-28322 Findings No findings were identified.

(3) Effectiveness of Corrective Actions On the basis of the corrective action documents reviewed, the inspectors concluded that the corrective actions were appropriate for the identified issues. Those corrective actions addressing selected NRC documented violations were also determined to be effective and timely. The inspectors review of the previous five years of the licensees efforts to address issues with the component cooling water system did not identify any negative trends or inability by the licensee to address long-term issues.

Observations The 5-year look back required by the inspection procedure was performed for the reactor recirculation system. The review looked for problems and issues back to 2008 that could be age-related. No age-related issues were identified, however, the system had been classified by the licensee as Maintenance Rule (a)(1) for not meeting licensee-established performance goals. The inspectors reviewed the licensees get-well program, including the issues (repetitive recirculation pump trips) that resulted in the (a)(1) classification. The issues were attributed to maintenance errors on the pumps.

The problems were such that trending would not have identified or prevented these issues. The pump trips were repetitive due to ineffective troubleshooting which failed to identify and correct the problems. The technical causes for the pump trips were not readily apparent, however. The licensee had increased the formality of troubleshooting and the maintenance-related problems were corrected.

Corrective actions appeared generally effective based on the samples the inspectors reviewed. However, the inspectors noticed several examples where the initial evaluations did not address or identify the cause of the issue. One was Card 11-20156, Maintenance Rule (MR) Get Well Plan for D11K610 is Ineffective (Apparent Cause),was supplemented by Card 11-27553, ACEs and MR Get Well Plan for D1100 SS-1 Computer Lockups Were Ineffective, however, the inspectors noted that the set of CARDS were self-identified; the licensee did identify the cause or causes of the computer problems eventually.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of its Operating Experience (OE)program. Specifically, the inspectors reviewed program implementing procedures, attended a weekly OE program meeting to observe the screening of OE information, discussed OE program activities with the facilitys OE coordinator, reviewed the completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

Specific documents reviewed are listed in the Attachment.

b. Assessment Based on reviewing three annual assessments of the OE program, portions of three work order packages, observing a weekly OE screening and assignment meeting, and reviewing the multiple performance indicators that displayed, among other items, OE review timeliness, quality, and backlog numbers, the inspectors determined that the licensee was adequately evaluating industry-operating experience for relevance to the facility. The licensee had entered applicable operating experience items into the corrective action program in accordance with station procedures. Both internal and external operating experience was being incorporated into station activities. Industry-operating experience was used to resolve equipment operational problems. The inspectors concluded that the licensee was appropriately evaluating industry-operating experience when performing root cause and apparent cause evaluations.

Observations The inspectors noted that the licensee was identifying and trending OE evaluations where the evaluation time was longer than their excellence goal of 120 days and trending corrective actions resulting from evaluations that were more than 365 days.

The inspectors noted that the licensee had identified several CARDS for which actions resulting from OE evaluations had not been completed. The inspectors observed that the licensee had lowered their excellence goal in April from 25 corrective action overdue items to zero and that the licensee had exceeded this threshold for July 2013. The inspectors recognized that the licensee identified that this threshold had been exceeded and documented the issue in their corrective action program (CARD 13-26338). The inspectors questioned the licensee on lowering the threshold. The licensee documented the inspectors observation into its CAP.

Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions through efforts from departmental assessments and audits. The inspectors reviewed Nuclear Quality Assurance (NQA) audits, departmental self-assessments, and departmental performance assessment reports. The inspectors also interviewed the NQA manager.

Specific documents reviewed are listed in the Attachment.

b. Assessment Based on the self-assessments and audits reviewed, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The audits and self-assessments were completed by personnel knowledgeable in the subject area, and the NQA audits were thorough and critical. The department self-assessments were acceptable, but were assessed by the inspectors to not be of as high a level of quality as the NQA audits. The inspectors observed that CAP items had been initiated for issues identified through NQA audits and self-assessments. The inspectors reviewed the self-assessment performed on the CAP and found no issues and generally agreed with the overall results and conclusions drawn.

Observations A review of the audit schedule indicated that it was appropriate and the CAP was used for issues identified. NQA appeared effective and intrusive based on number and nature of issues/recommendations. The self-assessment schedule appeared to be effective and added value to the organization. Corrective actions developed from assessments were captured for resolution in CARDs or the Action Item Management System (AIMS).

The audits/assessments seemed planned, comprehensive, and effective. The assessments appeared to be in compliance with existing procedures and requirements, with the assumption that compliance ensured an effective program. The inspectors observed that the licensee had benchmarked several of its processes against other USA Alliance (an inter-utility quality assurance cooperative) plants and plants outside of the USA Alliance.

The audits that were conducted at the end of each of the outages were accurate and detailed. The inspectors noted that the audits that covered items that have long cycle times did not reflect a longer period of review. An example was refueling (RF) outages; the licensee identified that foreign material exclusion (FME) issues in RF-14 were repeated in RF-15. The inspectors identified that FME issues identified in the audits occurred in RF-12, -14, and -15, the effectiveness of the actions from each audit were not reviewed for effectiveness except for the previous outage. In the case of the outage audits, the inspectors reviewed 4 outages to look for trends instead of 3 years as done by the licensee.

While the licensees self-assessments/audits appeared adequate and thorough, the inspectors identified an example where the licensee, in assessing a critical attribute from one of its self-assessments, did not clearly document the corrective action taken to address the deficiency. The licensee referenced another self-assessment memo and the fact that changes, i.e., corrective actions, could be reflected in the memo; however, a CARD was not initiated to capture the deficiency and/or recommendation and the corrective actions that were to be taken as directed by licensee procedure. The inspectors did not notice any other examples where deficiencies were not clearly documented in a CARD and actions were taken to address the deficiency, therefore it would be considered minor.

Findings No findings were identified.

.4 Assessment of Safety-Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors assessed the licensees SCWE through the reviews of the facilitys employee concerns program (ECP) implementing procedures, discussions with coordinators of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 2012 Safety Culture Survey and also briefly the overall results, as compiled by the licensee, from the twice per year Gallup surveys.

As part of the overall inspection effort, the inspectors discussed department and station programs with a variety of people. In addition, the inspectors interviewed approximately 31 individuals, in groups of 3 to 4 people, from various departments, to assess their willingness to raise nuclear safety issues. The individuals were non-supervisory personnel and were selected to provide a distribution across the various departments at the site. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also addressed changes in the plant environment over the past 2 years. Other items discussed included:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP;

• willingness to use the CAP; and

• knowledge and understanding of the ECP.

Assessment Interviews indicated that the licensee has an environment where people were generally free to raise nuclear safety issues without fear of retaliation. The documents provided to the inspectors regarding the SCWE surveys generally supported the conclusions from the interviews. All interviewees indicated that station personnel would raise nuclear safety issues although several interviewed groups said they might refrain from raising issues of low non-nuclear safety significance because their perception was that items of low significance might not be addressed to their satisfaction. All individuals knew that, in addition to the CAP, they could raise issues to their immediate supervision, the ECP, or the NRC.

Observations The inspectors reviewed the ECP log and two cases files. No issues were identified.

It was also noted that over the last 12 months there were a minimal number of allegations received by the NRC. The inspectors talked with the groups interviewed for SCWE about their use of the ECP. The groups interviewed stated that they were aware of the ECP but for the most part did not have need for the program because they could raise issues to their supervision or through their union.

The inspectors also talked with licensee human resources management about their use of a Gallup survey instrument. That instrument was being used to help in development of supervision but did have questions that could be indicative of the status of the SCWE.

The results shown to the inspectors appeared consistent with the interview results. The licensee also stated that they used in the results in quarterly meeting of a management committee that was responsible for monitoring nuclear safety culture.

From interactions with members of the licensees staff, the inspectors concluded that conditions do not exist that would be indicative of SCWE issues within the various organizations: maintenance, security, engineering, radiation protection, and operations.

However, in review of the 2012 of Nuclear Safety Culture Assessment report, the inspectors noted that the return rate of survey instruments was only 49.8 percent which, in the inspectors view, was below the return rate seen at other facilities. The rate was also lower than the rate from the previous assessment. The licensee agreed that the rate was low but did not have an explanation for the low return rate even though the assessment report recommended that the licensee should try to understand and correct the low return rate; the licensee wrote CARD 13-28306 to review the issue. The licensee did indicate that return rates for the Gallup survey instruments was in excess of 90 percent but indicated that they did put in much effort to have those survey instruments returned.

Findings No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On November 22, 2013, the inspectors presented the inspection results to Mr. T. Conner and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Conner, Site Vice President

K. Scott, Plant Manager

J. Ford, Director of Organizational Effectiveness

M. Caragher, Director Nuclear Engineering

E. Kokosky, Manager Nuclear Quality Assurance

K. Snyder, Manager Industry Interface

G. Strobel, Manager Operations

B. Rumons, General Supervisor Radiation Protection

D. Sadowyj, Corrective Action Program Lead Engineer

T. Thomas, Employee Concerns Program Coordinator

S. Bollinger, Manager Performance Improvement

R. Salmon, Supervisor Compliance/Licensing

P. Crane, Supervisor Work Management

Nuclear Regulatory Commission

B. Kemker, Senior Resident Inspector

P. Smagacz, Resident Inspector

LIST OF ITEMS

Opened/Closed

None Attachment