IR 05000395/2012008

IR 05000395-12-008, 09/10-28/2012, Virgil C. Summer Nuclear Station, NRC Problem Identification and Resolution Inspection Report

ML12349A166
Person / Time
Site:	Summer
Issue date:	12/14/2012
From:	Hooper G Reactor Projects Branch 7
To:	Gatlin T South Carolina Electric & Gas Co
References
IR-12-008
Download: ML12349A166 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 14, 2012

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2012008

Dear Mr. Gatlin:

On September 28, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station. The enclosed report documents the inspection findings, which were discussed with you and other members of your staff.

Subsequently, on October 31, 2012, an exit meeting was conducted by telephone to discuss the final results of this inspection with you, and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the problem identification and resolution, compliance with the Commissions rules, regulations, and with the 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 inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Virgil C. Summer Nuclear Station was adequate. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems.

Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from the industry operating experience were generally reviewed and applied when appropriate.

Audits and self-assessments were effectively used to identify problems and appropriate actions.

On the basis of the samples selected for review, the inspectors concluded that in general, problems were properly identified, evaluated, and corrected. There was one Green finding identified which was determined to be a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Virgil C. Summer Nuclear Station. In addition, if you disagree with the crosscutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement to the Regional Administrator, RII, and the NRC Senior Resident Inspector at the Virgil C. Summer Nuclear Station.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document 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/

George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12

Enclosure:

Inspection Report 05000395/2012008 w/Attachment: Supplemental Information

REGION II==

Docket No.: 50-395 License No.: NPF-12 Report No.: 05000395/2012008 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: September 10 - 28, 2012 Inspectors: N. Staples, Senior Project Inspector (Team Leader)

S. Ninh, Senior Project Engineer J. Eargle, Senior Reactor Engineer D. Terry-Ward, Construction Inspector R. Taylor, Senior Project Inspector Approved by: G. Hopper, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000395/2012-008; 09/10/2012 - 09/28/2012: Virgil C. Summer Nuclear Station;

Identification and Resolution of Problems.

The inspection was conducted by a senior reactor inspector, senior project engineer, two senior project inspectors, and a construction inspector. One Green non-cited violation (NCV) was identified. The significance of most findings is identified by their color (Green, White, Yellow,

Red) using IMC 0609, Significance Determination Process (SDP); cross-cutting aspects are determined using IMC 0310; Components Within the Cross-Cutting Areas; and findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Problem Identification and Resolution The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was generally effective at identifying problems and entering them into the corrective action program (CAP) for resolution. Generally, prioritization and evaluation of issues, formal root cause evaluations for significant problems, and corrective actions specified for problems were consistent with licensee CAP procedures. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.

The inspectors determined that audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, plant operations, and cause evaluations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

Cornerstone: Mitigating Systems

• Green: The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings. The licensee failed to ensure that the procedure for performing Preventative Maintenance (PM) deferrals included provisions to ensure that when a Work Order (WO) high value Preventative Maintenance Task Sheet (PMTS) is deferred past its end date that the new end date for the PMTS is updated in the Computerized Maintenance Management System (CMMS). Additionally, the licensee failed to ensure personnel performed PM deferrals when a WO high value PMTS could not be performed by its required end date as directed by the PM program procedure. The licensee entered the issue into the corrective action program as CRs 12-03940, 12-3930, 12-03931, 12-04122, and 12-04152.

The licensees failure to have an adequate procedure for PM deferrals and failure to perform PM deferrals as required by procedure SAP 143 was a performance deficiency.

The performance deficiency was determined to be more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, the failure to perform PMs at the required intervals could result in degradation or failure of safety significant equipment. The inspectors used IMC 0609, Att. 4, Initial Characterization of Findings, issued 6/19/12, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued 6/19/12, and determined the finding to be of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of system and/or function, did not result in exceeding a TS allowed outage time and did not represent an actual loss of function of one or more non-Tech Spec Trains. The team identified a cross-cutting aspect in the resources component of the human performance area because the licensee failed to ensure that the procedure was complete accurate and up to date.

H.2(c) (Section 4OA2 a.3)

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program (CAP)

(1) Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between October 2010 and September 2012, including a detailed review of selected CRs associated with the following risk-significant systems: Reactor Water Storage Tank (RW), Spent Fuel (SF), Safety Injection (SI) DC Emergency Power (EP), Radiation Monitoring (RM), and Nuclear Sampling (SS). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

Control Room walk-downs were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure SAP-1356, Cause Determination.

The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP. The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included CR Review Team (CRT)meetings and Management Review Team meetings (MRT).

Documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure SAP-0999, Corrective Action Program, management expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance.

Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP. However, the team identified one minor performance deficiency and one finding related to the identification of issues.

The inspectors identified a performance deficiency related to identification of issues.

The performance deficiency was screened in accordance with Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

The inspectors performed a review of CR-11-03515 which was initiated to conduct an apparent cause evaluation (ACE) for an NCV from a previous CDBI for the licensees failure to translate instrument uncertainties into the setpoints used in procedures. The inspectors determined that the licensee identified in the ACE that OE 22813 Updates To Uncertainty Calculations Were Not Being Properly Addressed, was applicable to the CR, and that the licensee had no documentation regarding their response to the OE.

The licensee took no further action related to the discovered applicability of OE 22813 or the lack of documentation found. The inspectors determined that the OE had been previously evaluated by the licensee and documented in the OE log, but that it was previously determined not to be applicable to the plant.

The team determined that the licensee failed to follow procedure SAP-0999, Corrective Action Program, Rev. 8, and procedure CDG-01, Cause Determination Guidelines, Rev.

15. Specifically, procedure SAP-0999, step 6.2.1 states, When an issue is recognized that it is not meeting a performance expectation, the event should be documented via a CR. Additionally, CDG-01, Previous Occurrence Evaluation, step 2 states If the same problem has occurred in the industry, determine if it has been previously evaluated here at VCS and document why our response to the OE was not successful in preventing the same condition here at VCS. Determine if the inadequate response to the OE was a cause or contributor to the current problem and what actions need to be taken to address the issue. The licensee initiated CR-12-04123 for the failure to identify and initiate a CR because the previous OE review was determined to be incorrect, and for the challenges in locating the identified OE in the OE log. Additionally, the licensee performed a review of instrument uncertainty documentation for instrument setpoints at VCS and determined that current setpoints were adequate and no setpoint corrections or adjustments were required.

The licensees failure to follow procedures SAP-0999 and CDG-01 was a performance deficiency. The inspectors determined the performance deficiency to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy since there was no impact on safety related setpoints due to the licensee not initiating a CR to evaluate the applicability of OE 22813.

Prioritization and Evaluation of Issues Based on the review of CRs sampled by the inspectors during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR categorization guidance in procedure SAP-0999. Each CR was assigned a priority level (category) by the CR Review Team and adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with procedure SAP-1356.

However, the inspectors identified that a minor performance deficiency, related to prioritization and evaluation of issues, attributed to an inadequate extent of condition (EOC). The performance deficiency was screened in accordance with Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

The inspectors performed a review of CR-11-03528 to determine if the screening and evaluation processes, as defined in procedure SAP-1356 and guideline CDG-01, were adequately implemented. The inspectors determined that the licensee failed to adequately evaluate and screen for an EOC as required by procedure SAP-0999.

Specifically, the licensee failed to perform an adequate EOC evaluation related to Cutler Hammer D26, normally energized (Hi Duty Cycle) critical relay deficiencies as identified in CR 11-03528.

The inspectors determined that the licensees failure to adequately screen for an extent of condition, as required by procedure SAP-0999, was a performance deficiency. The inspectors determined that this procedure was not an Appendix B procedure and no violation of NRC requirements was identified. The inspectors determined the performance deficiency to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy since there was no impact on always-energized Cutler Hammer D26 relays in safety-related systems. The licensee reopened and documented this issue in corrective action CR-11-03528 under action number 017.

The licensee also initiated CR-12-04028 and CR-12-03914 to address this issue.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

(3) Findings

Introduction:

The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. The licensee failed to ensure that the procedure for performing Preventative Maintenance (PM) deferrals included provisions to ensure that when a Work Order (WO) high value Preventative Maintenance Task Sheet (PMTS) is deferred past its end date that the new end date for the PMTS is updated in the Computerized Maintenance Management System (CMMS). Additionally, the licensee failed to ensure personnel performed PM deferrals when a WO high value PMTS could not be performed by its required end date as directed by the PM program procedure.

Description:

During a Component Design Basis Inspection in 2011, the inspectors determined that the licensee failed to perform PM WOs on the auxiliary fuel oil pump discharge check valves for the A and B emergency diesel generators (EDGs) that was due to be completed in 2006. The inspectors determined that the WO to disassemble, clean, and inspect valve XVC20956A-DG was not performed due to a lack of parts, and that the WO to disassemble, clean, and inspect valve XVC20956B was not performed because it was closed by mistake. The licensee entered this into their corrective action program with CR-11-00984 to document the inspectors concerns and evaluate the deferred WOs under procedure SAP-143, Preventative Maintenance Program, Rev. 15 which contained guidance for overdue WO class high value PMTS.

In 2012, the inspectors reviewed the licensees corrective actions associated with CR-11-00984 and determined that neither WO had been performed. The inspectors determined that the original WO for XVC20956A-DG did not receive a new end date in CMMS, therefore, the licensee did not have a mechanism to alert them that the WO was overdue. Additionally, the new WO for XVC20956B was not completed by the new end date of 7/26/2012, nor was a PM deferral or a subsequent evaluation performed in accordance with procedure SAP-143. The licensee entered this into their CAP with CRs 12-03930, and 12-03931 to determine if other PM WOs had been deferred without a new end date being entered into CMMS, and initiated CR 12-03940 to evaluate these deferred PMs using procedure SAP-143. This resulted in the identification of 77 high value PMs for safety related equipment that were not completed by their respective end dates. This included auxiliary check valves associated with the EDGs, SW motor oil coolers and circuit cards. The subsequent evaluations and review of these items determined that all of the components were verified operable by testing or inspection, and the deferred PMs did not represent an immediate safety concern. The inspectors determined that procedure SAP-143 did not contain guidance to require the licensee to assign a new end date in CMMS for deferred PMs. The licensee entered this into their CAP with CR-12-04122 and implemented interim actions to supplement procedure SAP-143 guidance to ensure that all overdue and deferral evaluation requests have an approved end date and that end date is translated into the CMMS.

Procedure SAP-143, section 6.12.3-A requires that if a WO Class High value PMTS cannot be performed by its required end date, that an evaluation for acceptability of the non-performance be performed in accordance with section 6.12.3-B for establishing a PM deferral. The inspectors questioned whether PM deferral evaluations were completed for the 77 overdue PMs as required by procedure SAP-143. This resulted in the identification of eighteen overdue PMs that did not have a deferral request or evaluation generated as required by procedure SAP-143, the most recent of which occurred in 2010. The licensee entered this into their CAP with CR 12-04152.

Analysis:

The licensees failure to have an adequate procedure for PM deferrals and failure to perform PM deferral evaluations as required by procedure SAP-143 was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, the failure to perform PMs at the required intervals could result in degradation or failure of safety significant equipment. In one example, the licensee determined that the service water pumps inboard and outboard bearing cooling coil replacement frequency, which had been exceeded, was based on the fact that they were exposed to the same failure mechanism and mode as the cooling coils that failed on a circulating water pump in 2008. The inspectors used IMC 0609, Att.

4, Initial Characterization of Findings, issued 6/19/12, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued 6/19/12, and determined the finding to be of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of system and/or safety function, did not result in exceeding a Technical Specification allowed outage time and did not represent an actual loss of function of one or more non-Technical Specification trains. The team identified a cross-cutting aspect in the resources component of the human performance area because the licensee failed to ensure complete, accurate, and up-to-date design documentations, procedures, and work packages, and correct labeling of components. H.2(c)

Enforcement:

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, since January 30, 2010, the licensee failed to have a procedure for PM deferrals that was appropriate to the circumstances, and failed to follow the existing procedural guidance. Specifically, procedure SAP-143 did not require the licensee to update CMMS with a new end date when a high value PM was deferred, and the licensee did not generate PM deferral requests and evaluations as required by procedure SAP-143. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance and was entered into the licensees corrective action program as CRs 12-03940, 12-3930, 12-03931, 12-04122, and 12-04152. Additionally, the licensee implemented interim actions to supplement procedure SAP-143 guidance to ensure that all overdue and deferral evaluation requests have an approved end date and that end date is translated into CMMS. (NCV 05000395/2012008-01, [Inadequate Procedures and Procedure Compliance for Preventative Maintenance Deferrals])

b. Assessment of the Use of Operating Experience

(1) Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure SAP-1351, Operating Experience Program, reviewed and selected CRs to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected a sample of operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since September 2010, to verify whether the licensee had appropriately evaluated each notification for applicability, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.

(2) Assessment Based on a review of documentation related to review of OE issues, the inspectors determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in all apparent cause and root cause evaluations in accordance with licensee procedure SAP-1356. However, the inspectors identified an issue in which the licensee was not following the guidance as described in procedure SAP-1356, Cause Determination, for receiving or screening vendor letters. Section 6.1.3 of procedure SAP-1356 requires that the OE specialist screens vendor letters and places those requiring evaluation into the CR system. The inspectors noted the OE specialist had not received or screened GE Technical Information Letters (TILs). The inspectors determined that the OE specialist not receiving and screening the TILs as required by procedure SAP-1356 was a performance deficiency. The inspectors determined that this procedure is not an Appendix B procedure and no violation of NRC requirements was identified. This issue was considered a minor finding because it was an administrative issue. The vendor letters had been forwarded to the plant system engineers for review and evaluation from the licensing personnel instead of the OE coordinator. The licensee documented this issue in the corrective action program as CR 12-03927.

(3) Findings No findings were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure SAP-0999. Documents reviewed are listed in the Attachment.

(2) Assessment The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that were initiated as a result of adverse trends.

(3) Findings No findings were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors randomly interviewed 16 on-site workers regarding their knowledge of the corrective action program at Virgil C. Summer Nuclear Station and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the inspectors reviewed a sample of CRs generated as a result of issues identified through the ECP to verify that concerns were being properly reviewed.

(2) Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) Findings No findings were identified.

4OA6 Exit

Exit Meeting Summary

On September 28, 2012, the inspectors presented the inspection results to Mr. Dan Gatlin and other members of the licensee staff. On October 31, 2012, a re-exit was conducted per phone call to discuss the final resolution of the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

A. Wright, Corrective Action Program

W. Martin, Nuclear Licensing

J. Archie, Senior Vice President, Nuclear Operations

D. Gatlin, Vice President, Nuclear Operations

K. Gore, Manager, Organizational / Development Effectiveness

C. McKinney, Nuclear Licensing

J. Nolting, Employee Concerns Program Coordinator

J. Weathersby, Supervisor, Nuclear Licensing

C. Calvert, Design Engineer

J. Heilman, Supervisor Corrective Action

J. Parler, Configuration Manager, Supervisor

W. Bishop, Procurement Engineer

V. Pearson, Engineering

N. Young, Engineering

C. Osier, Engineering

B. Morcutt, Electrical Supervisor

NRC personnel

J. Reese, Senior Resident Inspector

LIST OF ITEMS

OPENED, CLOSED

Opened and Closed

05000395/2012008-01 NCV Inadequate Procedures and Procedure Compliance For Preventative Maintenance Deferrals

Closed

None