IR 05000413/2004009
| ML042720403 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/24/2004 |
| From: | Haag R NRC/RGN-II/DRP/RPB1 |
| To: | Jamil D Duke Energy Corp |
| References | |
| IR-04-009 | |
| Download: ML042720403 (18) | |
Text
ber 24, 2004
SUBJECT:
CATAWBA NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2004009 AND 05000414/2004009
Dear Mr. Jamil:
On August 27, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station. The enclosed inspection report documents the inspection findings which were discussed on August 27, 2004, with you and other members of your staff.
The inspection examined activities conducted under your licenses as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, conducted plant observations, and interviewed personnel.
On the basis of the sample selected for review, there were no findings of significance identified during the inspection. The team concluded that, in general, problems were properly identified, evaluated, and corrected. It was noted that actions taken to correct equipment problems have sometimes been slow; but, increased management attention has been applied to equipment problems and increasing equipment reliability. There were also several instances identified where problems had not been promptly and/or thoroughly captured in Problem Investigation Process reports (PIPs). The lack of thoroughness and accuracy in these PIPs adversely impacted the proper coding of problems (especially human performance deficiencies) for trending and development of proper corrective actions.
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 NRCs document system
DEC 2 (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/
Robert C. Haag, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-413, 50-414 License Nos. NPF-35, NPF-52
Enclosure:
NRC Inspection Report 05000413/2004009 and 05000414/2004009 w/Attachment: Supplemental Information
REGION II==
Docket Nos: 50-413, 50-414 License Nos: NPF-35, NPF-52 Report No: 05000413/2004009, 05000414/2004009 Licensee: Duke Energy Corporation Facility: Catawba Nuclear Station, Units 1 and 2 Location: 4800 Concord Road York, SC 29745 Dates: August 9-27, 2004 Inspectors: K. Van Doorn, Senior Reactor Inspector, Lead Inspector A. Sabisch, Resident Inspector M. Scott, Senior Reactor Inspector R. Rodriquez, Reactor Inspector Approved by: R. Haag, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000413/2004009, 05000414/2004009; 08/09-27/2004; Catawba Nuclear Station;
Units 1 & 2; Identification and Resolution of Problems.
The inspection was conducted by two senior reactor inspectors, a resident inspector, and a reactor inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems The licensee was generally effective in identifying problems at a low threshold and entering them into the corrective action program. The licensee properly prioritized issues and routinely performed adequate evaluations that were technically accurate and of sufficient depth.
However, the licensee was slow at times to initiate Problem Investigation Process reports (PIPs) for documenting conditions adverse to quality that met the initiation criteria established in the program procedures. In addition, examples were identified where problems where not accurately and throughly described in PIPs; thereby, adversely impacting the licensees ability to properly code the problems for trending and develop proper corrective actions. This was especially true with respect to human performance deficiencies.
Several examples of recurring problems were noted after corrective actions had been completed. It was also noted that actions taken to correct equipment problems have sometimes been slow; but, licensee management applied increased attention to equipment problems and increasing equipment reliability through the Equipment Reliability Initiative started in early 2004. The licensees self-assessments and audits were effective in identifying deficiencies in the corrective action program. The inspectors did not identify any reluctance by plant personnel to report safety concerns.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a.
Effectiveness of Problem Identification
- (1) Inspection Scope The inspectors reviewed procedures associated with the Corrective Action Program (CAP), which described the administrative process for initiating and resolving problems via Problem Investigation Process reports (PIPs). The inspectors selected PIPs for review covering various cornerstones, risk significance, and site departments. The inspectors also conducted a detailed review of PIPs for four risk significant systems and risk significant components. The systems included the Auxiliary Feedwater System (CA), the Vital AC electrical system, the Emergency Diesel Generators (EDGs), and the Nuclear Service Water System (RN). Components included the Refueling Water Storage Tank (FWST) and components associated with flood events. For these selected systems/components, the inspectors reviewed associated system health reports, maintenance history, and completed Work Orders (WOs). PIPs associated with problems previously identified by the NRC were also selected for review. The inspectors also reviewed NRC inspection reports that documented NRC reviews over the last two years. This review was performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP.
The inspectors also conducted plant walkdowns of equipment associated with the selected systems/components to assess the material condition and to look for any deficiencies that had not been entered into the CAP.
The inspectors reviewed selected industry operating experience items associated with the systems/components, including NRC generic communications, to verify that these were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP.
The inspectors reviewed licensee self-assessments, including those which focused on problem identification and resolution to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.
The inspectors also attended various plant meetings to observe management and oversight functions of the corrective action process. These included daily site direction meetings, PIP screening meetings, and both the site and departmental Corrective Action Review Board (CARB) meetings. In addition, the inspectors reviewed CARB meeting results for the last two year period. The inspectors also held discussions with various personnel to evaluate their threshold for identifying issues and entering them into the CAP.
Documents reviewed are listed in the Attachment to this report.
- (2) Assessment The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP. In general, the threshold for initiating PIPs was low and employees were encouraged by management to initiate PIPs. Equipment performance issues were being identified at a low threshold level and entered into the CAP.
Self-assessments were self-critical and were effective in identifying value added issues that were entered into the CAP where appropriate. Site management was actively involved in the CAP process and focused appropriate attention on significant plant issues. The CARB meetings provided valuable insights and oversight of the CAP process.
The inspectors noted that the licensee was sometimes slow to initiate PIPs for documenting identified conditions adverse to quality. For the examples noted, the initiation criteria established in the CAP guidance procedures was met. Despite these issues being communicated to the licensee, PIPs were not initiated in a timely manner (i.e., CAP guidance states to initiate a PIP within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of identification.) Examples of untimely identification of issues in the CAP included PIPs C-04-4031, 04-4028, 04-3809, 04-1688, and 04-470.
For some PIPs, the licensee failed to thoroughly and accurately describe the issue and/or human performance attribute. An incomplete problem description was noted in PIPs C-04-3809 and 04-4028. Examples of the licensees failure to document human performance errors were reflected in PIPs C-04-4028, 04-3108, 04-2533, 04-1991,04-470, 04-1688, 03-5691, and 03-4815. The related problems, which typically involved technical procedural usage and adherence deficiencies, were considered to be low level issues not requiring any type of causal evaluation. These problems were usually captured in the lowest level (i.e., Action Category Level 4) PIPs, with no cause code identified. For example, PIP C-03-5691, which involved the failure to use the designated gauge when obtaining data for a CA pump test, was classified as a Level 4 with no mention of the human error. Operations management incorrectly considered this issue to be an effective use of self-check practices. Similarly, Category Level 4 PIP C-03-4815, involving an NRC-identified problem with debris in the containment sump, inappropriately stated that the procedure for sump inspection lacked sufficient detail when the procedure clearly required personnel to ensure debris was not present in the sump area. The PIP further stated that corrective actions would be completed as followup for NRC Bulletin 2003-01 regarding adequacy of containment sumps.
However, the procedure was not changed and additional minor problems were later noted when the sump was inspected. The failure to fully describe all aspects of a problem in the associated PIP, adversely impacted the licensees ability to properly code the problems for trending and develop proper corrective actions. As indicated by the number of PIPs identified above, this was especially true with respect to human performance deficiencies.
- (3) Findings No findings of significance were identified.
b.
Prioritization and Evaluation of Issues
- (1) Inspection Scope In conjunction with the inspections discussed in Section 4OA2a., the inspectors reviewed site trend reports, CAP backlogs, CAP performance indicators, and trend PIPs to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspectors assessed whether the licensee adequately determined the cause(s) of the problems, including root cause where appropriate, and adequately addressed operability, reportability, common cause, generic concerns, extent of condition, and extent of cause. The review also assessed whether the licensee appropriately identified corrective actions to prevent recurrence and if these actions had been appropriately prioritized.
- (2) Assessment The inspectors determined that the licensee had adequately prioritized issues entered into the CAP. Generally, the licensee performed evaluations that were technically accurate and of sufficient depth. The inspectors determined that site trend reports were thorough and a low threshold was established for evaluation of potential trends.
As noted in Section 4OA2a., a number of PIPs failed to document the human performance aspects of the issues. Despite these specific observations being discussed with the licesnee on several ocassions, their acknowlegement and evaluation to understand the extent of the problem has been slow.
For some problems, the licensee had been slow in completing corrective actions. The licensee had recognized this and was providing more management oversight via CARB for the more significant actions and, in general, increased management attention for more than minor issues, such as a management review of oldest PIPs. The inspectors noted that the licensee sometimes initiated a corrective action in a PIP to perform an evaluation whether a procedure or training problem exists rather than perform these types of evaluations as part of the problem evaluation prior to assignment of required corrective actions. This practice in some cases contributed to untimely development of corrective actions.
- (3) Findings No findings of significance were identified.
c.
Effectiveness of Corrective Actions
- (1) Inspection Scope The inspectors reviewed licensee effectiveness reviews and confirmed the implementation of various corrective actions associated with PIPs. For some of the PIPs discussed in Sections 4OA2a. and b., the inspectors assessed whether the licensee had identified and implemented timely and appropriate corrective actions to address problems. In addition, the inspectors provided special attention regarding status of corrective actions for PIPs C-01-884 and 01-3162, involving bio-fouling and corrosion of RN piping. The inspectors also reviewed a video tape inspection of the 42-inch diameter RN line from the lake to the pump house. The inspectors verified that the corrective actions were properly documented, assigned, and tracked to ensure completion.
- (2) Assessment In general, corrective actions developed and implemented for problems were timely, effective, and commensurate with the safety significance of the issues. Based on a review of NRC inspection results and equipment problems since the last Problem Identification & Resolution inspection (two years ago), the inspectors concluded that the licensee had sometimes been slow to correct equipment problems and fully recognize the extent of equipment reliability issues. However, licensee management had recognized equipment reliability as a significant issue requiring increased management attention as evidenced by the Equipment Reliability Initiative started in early 2004. Most of the major corrective actions associated with this initiative had been completed as of the current inspection and re-prioritization of equipment corrective actions had been performed.
Three examples of problems were noted that had corrective actions which were less than fully effective, in that, similar problems recurred after all corrective actions had been completed. The associated PIPs were C-04-4064, involving inadequacies in Operations freeze protection procedures, C-04-4031, involving radiation survey and posting errors, and C-03-4815, involving debris in the containment sump.
The licensee has been slow to develop final repairs for RN piping problems. However, inspections and development of RN piping problem corrective actions are ongoing and the licensee has established a new project team to provide increased attention for this problem.
- (3) Findings No findings of significance were identified.
d.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope 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 to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors also reviewed the licensees employee concerns program (ECP) which provides an alternate method to the CAP for employees to raise concerns and remain anonymous. The inspectors interviewed the ECP Coordinator and reviewed an ECP report and associated corrective actions to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
- (2) Assessment Based on this inspection and the PIP reviews, the inspectors concluded that licensee management emphasized the need for all employees to promptly identify and report problems using the appropriate methods established within the administrative programs.
The inspectors did not identify any reluctance to report safety concerns.
- (3) Findings No findings of significance were identified.
4OA6 Management Meetings
On August 27, 2004 the inspectors presented the inspection results to Mr. D. Jamil, Site Vice President, and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- D. Jamil, Vice President, Catawba Nuclear Station
- M. Glover, Station Manager
- B. Dolan, Engineering Manager
- W. Pitesa, Operations Manager
- C. Trezise, Maintenance Manager
- R. Sweigart, Safety Assurance Manager
- J. Foster, Radiation Protection Manager
- F. Smith, Chemistry Manager
- M. Patrick, Work Control Manager
- J. Thrasher, Modification Engineering Manager
- G. Hamrick, System Engineering Manager
NRC personnel
Eugene Guthrie, Senior Resident Inspector, Catawba
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Opened and Closed
None Previous Items
Closed
None
Discussed
None