IR 05000410/2017009
| ML17349A661 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/15/2017 |
| From: | Anthony Dimitriadis Division Reactor Projects I |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2017009 | |
| Download: ML17349A661 (20) | |
Text
ber 15, 2017
SUBJECT:
NINE MILE POINT - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000220 AND 05000410/2017009
Dear Mr. Hanson:
On November 17, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at Nine Mile Point Nuclear Station, Units 1 & 2. On that date, the NRC inspection team discussed the results of this inspection with Mr. Peter Orphanos, 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 also 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-220 and 50-410 License Nos.: DPR-63 and NPF-69
Enclosure:
Inspection Report 05000220 and 05000410/2017009 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-220 and 410 License Nos.: DPR-63 and NPF-69 Report Nos.: 05000220 and 05000410/2017009 Licensee: Exelon - Nine Mile Point, LLC Facility: Nine Mile Point Units 1 & 2 Location: Oswego, New York Dates: October 30 - November 17, 2017 Team Leader: R. Barkley, PE, Senior Project Engineer Inspectors: J. Schoppy, Senior Reactor Inspector J. Schussler, Resident Inspector, Ginna R. Rolph, Acting Resident Inspector, Nine Mile Point Approved by: Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
IR 05000220 and 05000410/2017009 - Biennial Baseline Inspection of Problem Identification and
Resolution.
This NRC team inspection was performed by two regional inspectors and two resident inspectors. No findings were identified during the inspection. 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 generally 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 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 (CAP) in a timely manner.
The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Nine Mile Point Unit 1 & 2 operations. In addition, based on those items selected for review, the inspectors determined that Nine Mile Point self-assessments and audits were thorough, and trending of relevant information was performed.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and employee concerns program (ECP) issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution (PI&R) 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 Exelons CAP at Nine Mile Point Station. To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, and Exelons procedure for Condition Reporting (PI-AA-120, Issue Identification and Screening Process, Revision 7). For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP). Additionally, the inspectors attended multiple Station Oversight Committee (SOC) and Management Review Committee (MRC) meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, and periodic trend reports. The inspectors also completed field walkdowns of various areas of the site, including many areas inside and outside the radiologically controlled areas (RCAs) at Unit 1 & 2. Additionally, the inspectors reviewed a sample of issue reports (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 condition reports issued since the last NRC Biennial PI&R inspection completed in the Fall of 2015. The inspectors also reviewed issue reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified.
The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes.
Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed Exelons completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected non-cited violations and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to elements of the Nine Mile Point Unit 2 Division I & II electrical system.
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 CAP at a low threshold. Exelon staff initiated over 20,000 issue reports between July 2015 and September 2017, of which approximately one third were later classified as Non-Corrective Action Program (NCAP) items. The inspectors observed supervisors at the SOC and MRC meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended many equipment and programmatic issues, and appropriately identified problems in issue reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the CAP as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated condition reports or removed old deficiency tags for issues that had since been corrected.
- (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 condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Exelons CAP implementing procedures appeared sufficient to ensure consistency in the categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.
However, the team did note one observation in Exelons prioritization and evaluation of the following issues:
Trending of Issue Report Data by the Radiation Protection Department The inspectors noted that the Radiation Protection (RP) department had not trended Issue Reports related to the departments activities for several years. This hampered the departments ability to promptly identify adverse trends in RP equipment or staff performance. For example, several Issue Reports were written about personnel clearing the ARGOS radiation monitors at the restricted area (i.e. RCA) boundary, but then alarming the portal contamination monitors at the security exit due to differences in the sensitivity of these monitors to specific radioactive isotopes. IRs 02539294 and 02544667 in 2015 and IRs 02685216 and 03955573 in 2016 are examples of individuals clearing the ARGOS monitors at the RCA egress point, but alarming portal monitors at the security exit. Another IR (#02723359 in 2016) involved an individual from Nine Mile Point alarming a portal monitor at the exit of another Exelon facility even though they did not enter the RCA of that facility. The inspector was concerned that this difference in detection sensitivity by the ARGOS monitors allowed for the possible spread of small amounts of radioactive contamination on personal clothing outside of the RCA. In response to the inspectors concern, IR 04070089 was issued on November 2, 2017, to address enhancements to the ARGOS detection capabilities to ensure that contamination is properly detected at the RCA boundary first. The inspectors noted that the RP department recently issued four other trend reports as they now have an individual assigned to perform such analyses.
- (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 concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective. The team noted the following minor violation of NRC regulations while performing this portion of the inspection:
In inspection report 05000220/2016001 and 05000410/2016001, the NRC identified a Green non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR)50.65(a)(4), when Exelon did not assess and manage the risk for online maintenance activities. Specifically, Exelon did not manage the risk associated with the unavailability of A residual heat removal minimum flow valves, which elevated plant risk from green to yellow. Exelon entered the violation into its CAP as IR 02673672. The inspectors reviewed the corrective actions associated with AR 02673672, which stated in part that a procedure change to both N2-TTP-RHS-4Y003 and N2-TTP-RHS-4Y002, A and B Residual Heat Removal System Heat Exchanger Performance monitoring (suppression pool cooling mode) procedures respectively, was to be implemented. The procedure change generated against N2-TTP-RHS-4Y003 added steps to capture component and system availability/unavailability relating to plant risk. The corrective action involving the change to the above two procedures was signed complete on August 11, 2016. Upon review of the procedures, the inspectors noted that there was not a procedure change request implemented for procedure N2-TTP-RHS-4Y002 due to an administrative oversight; only procedure N2-TTP-RHS-4Y003 was changed. However, the inspectors found that the unchanged procedure had not been used since the deficiency was identified.
The inspectors independently evaluated the deficiency for significance in accordance with the guidance in Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening and Appendix E, Examples of Minor Issues. The inspectors determined that not completely implementing the corrective action committed to was a deficiency of minor significance since the procedure had not been used since the deficiency was identified.
As a result it is not subject to enforcement action in accordance with the NRCs enforcement policy. This issue was captured in Exelons CAP as IR 04074701.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of condition reports associated with the review of industry operating experience to determine whether Exelon appropriately evaluated the operating experience information for applicability to Nine Mile Point 1 and/or 2 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 its CAP. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b. Assessment The inspectors determined that Exelon appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during various meetings and pre-job briefings.
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 CAP and departmental functional area assessments. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the CAP, 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 self-revealing and NRC-identified observations made during the inspection.
b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical and thorough, and in several cases 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 some self-assessments to a sufficient depth to identify issues which were then entered into the CAP 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 Nine Mile Point. 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 ECP manager to determine what actions were implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed selected ECP files to ensure that Exelon entered issues into the corrective action program when appropriate.
b. Assessment During interviews with individual team members, Nine Mile Point staff expressed a willingness to use the CAP 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 CAP and the ECP. The 2015 safety culture survey (the most recent available) was also reviewed and it also reflected a willingness of employees to raise safety concerns.
While the sites issue reporting system does not afford employees the opportunity to submit condition reports anonymously, a majority of the individuals surveyed thought that such reports could be submitted. However, none felt the need to submit an IR in such a manner. If an individual contacts the ECP program, it is possible for the ECP Manager to submit an IR anonymously on their behalf. Exelon moved to communicate this misconception to its staff upon identification.
In addition, NRC allegation activity at Nine Mile Point since the last PI&R has remained low. Based on these limited interviews as well as the survey data and a review of the ECP case history since 2015, 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 November 17, 2017, the inspectors presented the inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the Nine Mile Point 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
Exelon Personnel
- S. Baldwin, Supervisor Maintenance, NMP Mechanical Maintenance
- G. Carter, U1 Operations Shift Manager
- B. Deets, Equipment Operator, U2 Operations
- P. Fischer, Security Programs Lead
- P. Foti, Senior Reactor Operator, U2 Operations
- R. Franklin, Senior Engineer
- C. Grapes, U1 Operations Shift Manager
- K. Higgins-Asmus, Senior Reactor Operator, U1 Operations
- B. Hinckley, Reactor Operator, U1 Operations
- S. Homoki, Senior Engineer
- K. Johnson, Senior Engineer
- C. Jones, U2 Operations Shift Manager
- J. McMahon, Equipment Operator, U1 Operations
- D. Pokon, Senior Engineer
- R. Pritchard, Regulatory Assurance
- T. Proud, Operations Department CAPCO
- T. Sprouse, Engineer
- R. Staley, Senior Engineering Analyst
- E. Vosbury, Site CAP Manager, Senior Regulatory Specialist
NRC Personnel
- E. Miller, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened/Closed
None