IR 05000348/2014011
| ML14259A286 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/16/2014 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Gayheart C Southern Nuclear Operating Co |
| Linda K. Gruhler 404-997-4633 | |
| References | |
| IR-2014-011 | |
| Download: ML14259A286 (14) | |
Text
September 16, 2014
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC 95001 SUPPLEMENTAL INSPECTION REPORT 05000348/2014011; 05000364/2014011
Dear Ms. Gayheart:
On August 14, 2014, the U.S. Nuclear Regulatory Commission (NRC) staff completed a supplemental inspection at your Joseph M. Farley Nuclear Plant. The enclosed report documents the results of this inspection that was discussed with you, and members of your staff, during an exit meeting on August 14, 2014.
As required by the NRC Reactor Oversight Process (ROP), this supplemental inspection was performed in accordance with Inspection Procedure 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area. The purpose of the inspection was to determine causes for, and actions taken, related to a finding of low to moderate safety significance (White) in the Emergency Preparedness cornerstone. This issue was documented previously in NRC Inspection Report (IR) 05000348/2013005; 05000364/2013005. On April 21, 2014, you informed the NRC that Farley Nuclear Plant was ready for the supplemental inspection.
The NRC performed this supplemental inspection to determine if: (1) the root causes and contributing causes for the identified issues were understood, (2) the extent of condition and extent of cause of risk-significant performance issues were identified, and (3) your completed or planned corrective actions were sufficient to address and prevent repetition of the root and contributing causes. The NRC also conducted an independent review of the extent of condition and extent of cause for the White finding, and an assessment of whether any safety culture component caused, or significantly contributed, to the performance issue.
The NRC determined that the root and apparent cause evaluations were conducted to a level of detail commensurate with the significance of the problems, and reached reasonable conclusions as to the root and contributing causes of the event. The NRC also concluded that you identified reasonable and appropriate corrective actions for each root and contributing cause, and that the corrective actions appeared to be prioritized commensurate with the safety-significance of the issues. Based on the results of this inspection, no findings were identified.
After reviewing the performance in addressing the White finding documented in this inspection report, the NRC concluded your actions met the inspection objectives. As ROP discretion was exercised in enforcement of this issue and was not to be considered in assessing plant performance, the White finding is closed and Farley Nuclear Plant remains in the Licensee Response Column of the ROP Action Matrix.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Public inspections, exemptions, requests for withholding, of the NRCs Rules of Practice, a copy of this letter, its Enclosure, and your response, (if any), will be available electronically for public inspection in the NRC Public Document Room, or from the Publicly Available Records (PARS) component of NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Brian R. Bonser, Chief
Plant Support Branch 1
Division of Reactor Safety
Docket Nos. 50-348 and 50-364 License Nos. NPF-2 and NPF-8
Enclosure:
IR 05000348/2014011 and 05000364/2014011 w/Attachment: Supplementary Information
REGION II==
Docket Nos:
05000348 and 05000364
License Nos:
Report Nos:
05000348/2014011 and 05000364/2014011
Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Joseph M. Farley Nuclear Plant, Units 1 and 2
Location:
Columbia, AL
Dates:
August 12 - 14, 2014
Inspectors:
M. Speck, Senior Emergency Preparedness Inspector
S. Sanchez, Senior Emergency Preparedness Inspector
Approved by:
Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety
SUMMARY
IR 05000348/2014011, 05000364/2014011; 08/12/2014 - 08/14/2014; Joseph M. Farley
Nuclear Plant; Supplemental Inspection - Inspection Procedure (IP) 95001 Two regional emergency preparedness inspectors performed this inspection. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Emergency Preparedness
The NRC staff performed the supplemental inspection in accordance with IP 95001,
Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, to assess the licensees evaluation associated with the calculation error used to develop threshold values for Emergency Action Levels (EALs) RG1 and RS1, as required by 10 CFR 50.54(q) and the licensees emergency plan. This error resulted in the EAL threshold values being approximately 60 times the appropriate values from 2007 until 2013. The NRC staff previously characterized this issue as having low to moderate safety-significance (White), as documented in NRC IR 05000348/2013005; 05000364/2013005.
During this inspection, the inspectors determined that your staff performed an adequate evaluation of the cause of the White finding. Your staffs evaluation identified the root cause to be that engineering personnel did not utilize adequate verification practices in developing calculations used to establish threshold values for EALs. The inspectors found the extent of condition and extent of cause reviews were adequate, and the corrective actions implemented were adequate. All immediate and long term corrective actions have been completed except for: (1) inclusion of the details of this issue as an operating experience discussion item in the design bases calculation course; (2) performance of self-assessments to confirm that current standards are met or exceeded for safety analysis calculations; (3) review errors identified in the performance of the key calculations review to determine the significance and frequency of the errors; (4) complete corrective action effectiveness reviews; and (5) development and implementation of a method for resourcing, managing, and prioritizing the Safety Analysis Groups (SAG) workload.
REPORT DETAILS
OTHER ACTIVITIES
4OA4 SUPPLEMENTAL INSPECTION
.01 Inspection Scope
The NRC staff performed this supplemental inspection in accordance with Inspection Procedure (IP) 95001 to assess the licensees evaluation of a White finding that affected the emergency preparedness cornerstone in the reactor safety strategic performance area. The inspection objectives were to provide assurance that the:
- root causes and contributing causes of risk-significant performance issues were understood
- extent of condition and extent of cause of risk-significant performance issues were identified
- licensees corrective actions for risk-significant performance issues were sufficient to address the root and contributing causes and prevent recurrence The finding was characterized as having (White) safety-significance as discussed in NRC Inspection Report (IR) 05000348, 05000364/2013005, and was associated with radiation monitor Emergency Action Level (EAL) threshold values for radiological release (RS1 and RG1) being approximately 60 times the appropriate value. The NRC exercised discretion in determining that the issue met the criteria specified in Inspection Manual Chapter (IMC) 0305 for treatment as an old design issue, and would not aggregate in the Reactor Oversight Process (ROP) Action Matrix. The condition was found to have existed from 2007 until 2013.
The licensee informed the NRC staff on April 21, 2014, that they were ready for the supplemental inspection. In preparation for the inspection, the licensee performed a root cause investigation, documented Root Cause Report 210594, to identify weaknesses that existed in various organizations and processes that resulted in the risk-significant (White) finding.
The inspectors reviewed the licensees Root Cause Evaluation (RCE) and other assessments conducted in support of, and as a result of, the investigation. Corrective actions taken to address the identified root and contributing causes were also reviewed.
Additionally, inspectors interviewed licensee personnel to ensure that the root and contributing causes and the contribution of safety culture components, were understood, and corrective actions were appropriate to address the causes and preclude repetition.
.02 Evaluation of Inspection Requirements
02.01 Problem Identification a.
Determine that the evaluation identifies who identified the issue and under what conditions the issue was identified.
The licensee identified the engineering calculation errors during an internal operating experience review. The licensee entered the issue into their corrective action program (CAP), developed immediate compensatory measures to provide appropriate EAL threshold values to appropriate decision-makers, and initiated appropriate apparent and root cause investigations. The inspectors verified that this information was documented in the licensees evaluation.
b.
Determine that the evaluation documents how long the issue existed and prior opportunities for identification.
The licensee identified that the RG1 and RS1 EAL radiation monitor threshold values were in error from when they were incorporated into plant procedures in April 2007 until corrected in May 2013. The licensee did not identify any prior opportunities for identification.
The inspectors determined that the licensees evaluation and assessments were adequate with respect to identifying how long the issue existed and the prior opportunities for identification. The inspectors did not identify any missed opportunities.
c.
Determine that the evaluation documents the plant-specific risk consequences, as applicable, and compliance concerns associated with the issue.
The NRC determined this issue was a White finding, as documented in NRC IR 05000348, 364/2013005 dated February 14, 2014. The licensees RCE documented the consequences of the issue, including potential adverse impacts on the ability of decision-makers to evaluate the effects of events during an emergency, and the licensees responsibility to protect the health and safety of the public. Upon discovery, the licensee took action to implement corrective actions to establish appropriate threshold values.
The inspectors concluded that the licensee appropriately documented the risk consequences and compliance concerns associated with the finding.
d. Findings
No findings were identified.
02.02 Root Cause and Extent of Condition Evaluation a.
Determine that the problem was evaluated using a systematic methodology to identify the root and contributing causes.
The licensees investigation was performed by a diverse qualified team of seven members using licensee procedure NMP-GM-002-GL03, Cause Analysis and Corrective Action Guidelines. The following systematic methods and tools were used to perform the RCE:
- Event and Causal Factor Chart Analysis
- Barrier Analysis
- Interviews
- Extent of Condition and Extent of Cause Evaluations
- Human Performance Checklist
- Change Summary Chart
- Safety Culture Attributes Assessment
- Organization and Programmatic Review The licensee used an independent team to perform a mock inspection in July 2014 to determine their readiness for inspection, and the need for additional corrective actions.
The inspectors determined that the licensee adequately evaluated the issue using systematic methodologies to identify root and contributing causes.
b.
Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem.
The RCE was detailed in the scope of investigation and performed the following
activities in support of the evaluation:
- Conducted interviews with key personnel involved with the issue
- Performed searches and reviews of the corrective action database for Emergency Preparedness identified items, Training department lesson plans and supporting documents; to include Emergency Preparedness, Work Control, and Operations procedures
- Performed reviews of industry operating experience, internal operating experience, and emergency preparedness internal change documentation.
The following represent a synopsis of the root cause and contributing causes:
- (1) The root cause of this issue was determined to be inadequate independent verification practices. Proper verification practices were not demonstrated by the preparer or the reviewer of the calculation in 2004, nor were these practices enforced by the Safety Analysis Groups (SAG) supervisory personnel.
- (2) A mathematical error associated with the conversion factor was determined to be a direct cause of this issue. Due to over confidence, the preparer did not include the derivation of the conversion factor in the body of the calculation, and the error was not identified by the reviewer. The reviewer placed too much reliance on the preparers ability and did not perform a complete review.
- (3) Organizational structure and lack of cross functional communication were determined to be causal factors. Although procedural guidance was in place to ensure adequate detail when performing key calculations, supervision was insufficiently engaged with the SAG to enforce this guidance. In addition, communications between the SAG
and the receiving organization were not implemented to ensure the intent and results of the calculation were adequate.
Based on a review of the RCE and supporting documentation, the inspectors concluded that the evaluation was conducted to a level of detail commensurate with the significance of the problem.
c.
Determine that the root cause evaluation included a consideration of prior occurrences of the problem and knowledge of prior operating experience.
The RCE included a review of plant corrective action databases and industry databases.
The licensee identified four CAP items related to errors in calculations originated after 2008, but determined the errors were non-consequential. Additionally, the licensee determined that the implementation of calculation training since 2007 demonstrated the effectiveness of that training in limiting the severity of identified errors. The licensee identified several industry issues associated with EAL setpoints and Nuclear Energy Institute (NEI) 99-01 Rev. 4 implementation; however, the timeframe and specific issues identified in these issues show that use of this operating experience would not have prevented the calculation error.
Based on the licensees detailed evaluation and conclusions, the inspectors determined
that the licensees root cause investigation included adequate consideration of prior
occurrences of the problem, and knowledge of prior operational experience.
d.
Determine that the root cause evaluation addressed the extent of condition and the
extent of cause of the problem.
The licensees evaluation limited the extent of condition review to EAL calculations as these calculations were similar in content and also performed by the SAG. Search results were restricted to core business calculations with dose as a keyword in the title.
This produced a result of 202 calculations that were further reduced to 47 calculations based on additional analysis by the licensee. Two calculations were identified to be performed by the same preparer as in 2004, but a review of these calculations did not identify any other unit conversion errors. Additional licensee review of underlying assumptions supporting EAL threshold value determinations did identify several other values, which required minor revisions. These were placed in the licensees CAP and with actions completed.
The extent of cause was limited to the verification practices of the SAG. Procedure NMP-ES-039-001, Calculations - Preparation and Revision, sets the standard for ensuring rigor, the level of detail, and accuracy when performing key calculations. Also, procedures are in place to ensure individuals are qualified to perform calculations and products are reviewed and verified.
The inspectors concluded that the licensees root cause investigation adequately addressed the extent of condition and the extent of cause of the issue. A review of the subsequently identified EAL issues did not reveal any new performance deficiencies (PDs).
e.
Determine that the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components as described in Inspection Manual Chapter 0305.
The licensee found weaknesses in the following crosscutting aspects:
- HU (human) component of Work Control H3(b)]: This related to the ineffective oversight failing to adequately prioritize and risk-rank SAG work.
- HU component of Work Practices H4(c)]: This related to the ineffective oversight to ensure adequate verification practices were used by engineers involved in calculations supporting EAL threshold development.
The inspectors determined that the licensees root cause investigation included a proper consideration of whether weaknesses in any safety culture component were root or significant contributing causes of the issue.
f. Findings
No findings were identified.
02.03 Corrective Actions
a.
Determine that appropriate corrective actions are specified for each root and contributing
cause or that the licensee has an adequate evaluation for why no corrective actions are
necessary.
The licensee identified the following root cause and implemented the corresponding
corrective action:
- The licensee identified the root cause to be poor independent verification practices compounded by causal factors of inadequate organizational structure, and lack of cross functional communication. For a corrective action to prevent recurrence (CAPR), the SAG was transferred from Fleet Licensing to Fleet Design in December of 2007. This was done to ensure proper technical oversight of engineering calculations existed, and that procedural standards were adequately enforced. An additional CAPR was the development and implementation of a training course in 2007 that established the foundation for correct verification practices when performing design bases calculations. The corrective action to address the lack of cross functional communication was addressed by revising procedure, NMP-ES-050, Request for Engineering Review, to require communications between responsible organizations throughout the calculation revision process.
The licensee developed corrective actions to address contributing causes as
summarized below:
- The technical inaccuracies in the EAL calculations were addressed by the licensee performing a reconstitution of the NEI 99-01 Rev. 4, EAL Calculations for the Farley Nuclear Plant, which was completed in July 2014.
- Communications with corporate design engineers, site design engineers, and external engineering firms to discuss the issue, reinforce procedural standards, and emphasize the importance of calculation accuracy and review was completed in March 2014.
The inspectors determined that the corrective actions were appropriate, and addressed the root and contributing causes in the licensees detailed evaluation and conclusions.
b.
Determine that corrective actions have been prioritized with consideration of risk-significance and regulatory compliance.
The licensee determined the correct EAL threshold values and provided these to appropriate decision-makers in the operations, and emergency response organizations (EROs). The licensee completed apparent cause and RCE, and a subsequent independent assessment to determine root/contributing causes, and developed appropriate corrective actions with consideration of risk-significance.
The inspectors determined that the immediate and follow-on corrective actions were adequately prioritized with consideration of the risk-significance and regulatory compliance.
c.
Determine that a schedule has been established for implementing and completing the corrective actions.
The licensee established due dates for the corrective actions in accordance with their CAP. The inspectors reviewed the status of each corrective assignment and determined that an appropriate schedule had been established for implementing the corrective actions, with the only remaining actions being:
- (1) inclusion of the details of this issue as an operating experience discussion item in the design bases calculation course; (2)performance of self-assessments to confirm that the current standards are being met or exceeded for safety analysis calculations;
- (3) review errors identified in the performance of the key calculations review to determine the significance and frequency of the errors;
- (4) complete corrective action effectiveness reviews; and
- (5) development and implementation of a method for resourcing, managing, and prioritizing the SAGs workload.
d.
Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence.
The licensee established an effectiveness review plan. Final effectiveness reviews are scheduled to be completed by January 15, 2015.
The inspectors determined that the effectiveness review plan actions would adequately test and/or measure corrective actions to ensure minimal impact from future calculation errors.
e.
Determine that the corrective actions planned or taken adequately address a Notice of Violation that was the basis for the supplemental inspection, if applicable.
As ROP discretion was exercised, no written response to the Notice of Violation (NOV)was required. The licensees evaluation described:
- (1) corrective actions taken and the results achieved;
- (2) actions which will be taken;
- (3) the date when full compliance was achieved; and
- (4) the reasons for the violation. During this inspection, the inspectors confirmed that the licensees root cause investigation, and actions completed or planned, adequately addressed the NOV. The licensee restored full compliance on July 12, 2013, when final EAL thresholds were incorporated in appropriate Emergency Preparedness procedures.
f. Findings
No findings were identified.
02.04 Evaluation of Inspection Manual Chapter 0305 Criteria for Treatment of Old Design
Issues.
This issue was previously evaluated against IMC 0305 criteria and was determined to be
an old design issue.
4OA6 Exit Meeting
On August 14, 2014, the inspectors presented the inspection results to Ms. C. Gayheart and other members of the staff who acknowledged the results. The inspectors asked the licensee if any of the material examined during the inspection should be considered proprietary. The licensee did not identify any proprietary information.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee
- W. Evans, Principal Engineer - Nuclear Safety Analysis
- D. Lambert, Manager - Fleet Design Mechanical, Stress, and Hazards
- D. Johnson, System Engineer
- H. Cooper, Engineering Programs Supervisor - Root Cause Team Leader
- L. Fields, Senior Engineer and Root Cause Analyst
- D. Drawbaugh, EP Manager
- C. Gayheart, Site Vice President
- K. Johnson, Lead Engineer Fleet Design - Civil and Seismic
- D. Hildebrandt, Operations Shift Supervisor
- B. Payne, Operations Shift Manager
- G. Wilson, Operations Shift Supervisor
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened
None
Closed
- 05000348-364/2013005-01; Calculation Error Results in Significantly non-Conservative EAL Threshold Values