IR 05000413/2014007
| ML14325A102 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/21/2014 |
| From: | Steven Rose Division Reactor Projects II |
| To: | Henderson K Duke Energy Carolinas |
| References | |
| IR 2014007 | |
| Download: ML14325A102 (15) | |
Text
UNITED STATES ber 21, 2014
SUBJECT:
CATAWBA NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2014007 AND 05000414/2014007
Dear Mr. Henderson:
On October 23, 2014, the Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Catawba Nuclear Station, Units 1 and 2.
The inspection team documented the results of this inspection in the enclosed inspection report.
Based on the inspection sample, the inspection team determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.
The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.
Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available.
The NRC inspectors did not identify any findings or violations of more than minor significance. In accordance with 10 CFR 2.390 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 the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Steven D. Rose, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52
Enclosure:
IR 05000413/2014007 and 05000414/2014007 w/Attachment: Supplemental Information
REGION II==
Docket No.: 50-413, 50-414 License No.: NPF-35, NPF-52 Report No: 05000413/2014007, 05000414/2014007 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station, Units 1 and 2 Location: York, SC 29745 Dates: October 6 - 10, 2014 October 20 - 23, 2014 Inspectors: B. Bishop, Project Engineer, Team Leader R. Taylor, Senior Project Inspector N. Staples, Senior Project Inspector J. Quinones, Project Engineer Approved by: Steven D. Rose, Branch Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY
IR 05000413/2014007, 05000414/2014007; 10/06/2014 - 10/23/2014; Catawba Nuclear
Station, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by two senior project inspectors and two project engineers. 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 (ROP), Rev.
5.
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall 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, and plant operations.
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.
The NRC inspectors did not identify any findings or violations of more than minor significance.
REPORT DETAILS
4OA2 Problem Identification and Resolution
1. Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed the licensees Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of PIPs. To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the team reviewed a sample of Problem Investigation Programs (PIPs) that had been issued between October 2012 and September 2014, including a detailed review of selected PIPs associated with the following risk-significant systems and components: Auxiliary Feedwater, Emergency Diesel Generators, and Nuclear Service Water. Where possible, the team independently verified that the corrective actions were implemented as intended. The team also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the team selected a representative number of PIPs that were identified and assigned to the major plant departments, including quality assurance, health physics, chemistry, emergency preparedness and security. These PIPs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected PIPs, verified corrective actions were implemented, and attended meetings where PIPs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
Plant walkdowns of equipment within the selected systems listed above and other plant areas were conducted by inspectors to assess the material condition and to identify deficiencies that had not been previously entered into the CAP. The team reviewed PIPs, 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, a five-year review was performed for selected systems to identify trends and age related issues.
Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were being tracked to resolution. A sample of operator workarounds and operator burden screenings were reviewed and the team verified compensatory measures for deficient equipment were being implemented in the field.
Detailed reviews of selected PIPs were performed by the inspectors to assess the adequacy of root-cause and apparent-cause evaluations for identified problems. The team reviewed these evaluations against the descriptions of the problem described in the PIPs and the guidance in licensee procedures AD-PI-ALL-0101, Root Cause Evaluation, and AD-PI-ALL-0102, Apparent Cause Evaluation. The team assessed if the licensee had adequately determined the cause(s) of identified problems, and 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 as applicable.
The team reviewed selected industry operating experience (OE) items, including NRC generic communications and Part 21 reports, to verify that they had been appropriately evaluated for applicability or used in licensee activities and that issues identified through these reviews had been entered into the CAP.
The team reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
Various plant meetings were attended by the team to observe management oversight functions of the corrective action process. These included meetings for the Centralized Screening Team (CST) and Performance Improvement Oversight Committee (PIOC).
b. Assessment Problem Identification The team 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 PIPs as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program, managements expectation that employees were encouraged to initiate PIPs for any reason, and the lack of deficiencies identified by the team during plant walkdowns not already entered into the CAP. 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 team determined that system deficiencies were being identified and placed in the CAP.
Problem Prioritization and Evaluation Based on the review of PIPs sampled by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the PIP severity level determination guidance in procedure AD-PI-ALL-0100, Corrective Action Program. Each PIP was assigned a severity level at the CST meeting, and this determination was reviewed at the CAP Review meeting. Adequate consideration was given to system or component operability and associated plant risk.
The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and the assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending upon the type and complexity of the issue consistent with licensee procedures.
Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that generally, 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, PIPs, 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 effective.
2. Use of Operating Experience
a. Inspection Scope
The team examined the licensees use of industry OE to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems at the plant. In addition, the team selected 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 October 2012 to verify whether the licensee had appropriately evaluated each notification for applicability to the Catawba Nuclear Station, and whether issues identified through these reviews were entered into the CAP.
b. Assessment Based on a review of documentation related to OE issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was screened by the corporate OE coordinator and relevant information was then forwarded to the sites OE coordinator. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in root cause evaluations and apparent cause evaluations in accordance with licensee procedures AD-PI-ALL-0101, Root Cause Evaluation, and AD-PI-ALL-0102, Apparent Cause Evaluation.
3. Self-Assessments and Audits
a. Inspection Scope
The team 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 AD-PI-ALL-0300, Self-Assessment and Benchmark Programs.
b. Assessment The team 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 team verified that PIPs were created to document 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.
4. Safety-Conscious Work Environment
a. Inspection Scope
During the course of the inspection, the team assessed the stations safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
b. Assessment Based on the interviews conducted and the PIPs reviewed, the team 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 upon interviews conducted with a sample of plant employees from various departments, the team determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The team did not identify any reluctance on the part of the licensee staff to report safety concerns.
4OA6 Meetings, Including Exit
On October 23, 2014, the inspectors presented the inspection results to you and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- B. Cauthen, Lead Nuclear Engineer
- J. Constant, Lead Cause Analysis Specialist
- N. Flippin, Nuclear Online Manager
- B. Foster, NOS Manager
- T. Hamilton, General Manager Engineering
- R. Hart, Regulatory Affairs Manager
- K. Henderson, Site Vice-President
- W. M. Hogan, Principal Nuclear Engineer
- C. Kamilaris, Organizational Effectiveness Director
- T. Owusu, Sr. Nuclear Engineer
- T. Pasour, Regulatory Affairs
- K. Robinson, Performance Improvement Manager
- M. Rott, Nuclear Employee Concerns Consultant
- D. Shever, Nuclear Engineer II
- P. Simbrat, Regulatory Affairs
- P. Simpson, Sr. Nuclear Engineer
- T. Simril, Plant Manager
- S. Wallace, Nuclear OE/ICES Specialist
NRC personnel
- A. Hutto, Senior Resident Inspector
- S. Rose, Chief, Branch 7, Division of Reactor Projects
LIST OF REPORT ITEMS
Opened and Closed
None