IR 05000413/2022011

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Biennial Problem Identification and Resolution Inspection Report 05000413/2022011 and 05000414/2022011
ML22343A232
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 12/15/2022
From: Eric Stamm
NRC/RGN-II/DRP/RPB1
To: Simril T
Duke Energy Carolinas
References
IR 2022011
Download: ML22343A232 (12)


Text

December 15, 2022

SUBJECT:

CATAWBA NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2022011 AND 05000414/2022011

Dear Tom Simril:

On November 17, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Catawba Nuclear Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution 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 problem identification and resolution 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 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.

No findings or violations of more than minor significance were identified during this inspection. 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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Stamm, Eric on 12/15/22 Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000413 and 05000414 License Nos. NPF-35 and NPF-52

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000413 and 05000414 License Numbers: NPF-35 and NPF-52 Report Numbers: 05000413/2022011 and 05000414/2022011 Enterprise Identifier: I-2022-011-0028 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station Location: York, South Carolina Inspection Dates: October 31, 2022, to November 17, 2022 Inspectors: M. Checkle, Senior Allegations Coordinator D. Jackson, Senior Project Engineer N. Lacy, Operations Engineer D. Rivard, Resident Inspector E. Robinson, Project Engineer Approved By: Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Catawba Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000414/2022-001-00 LER 2022-001-00 for 71153 Closed Catawba Nuclear Station,

Unit 2, Manual Reactor Trip and Auxiliary Feedwater Start due to Misaligned Control Rods

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution (PI&R) program in identifying, prioritizing, evaluating, and correcting problems.

The inspectors conducted an in-depth corrective action program review of the following systems/components or portions thereof: auxiliary feedwater, emergency diesel generators, nuclear service water, standby shutdown facility. The inspectors also conducted a five-year review of equipment aging issues.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event report (LER):

(1) LER 05000414/2022-001-00, Catawba Nuclear Station, Unit 2, Manual Reactor Trip and Auxiliary Feedwater Start due to Misaligned Control Rods (ADAMS Accession No. ML22173A172). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

INSPECTION RESULTS

Assessment 71152B 1) Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program (which includes the work management system), and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.

Problem Prioritization and Evaluation: Based on the review of condition reports, work orders, and work requests, the inspectors concluded that problems were prioritized and evaluated in accordance with licensee guidance. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that, in general, plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors 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. The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused.

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.

2) Operating Experience The team determined that the stations processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.

3) Self-Assessments and Audits The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that action requests were created to document areas for improvement and findings, and verified that actions generally had been completed consistent with those recommendations.

However, the inspectors noted that during the licensees 2020 PI&R readiness self-assessment, the licensee identified that both the work order backlog biennial assessment, and the annual work order and work request backlog review, had not been completed for 2019 and 2020, respectively, as required by AD-WC-ALL-0200, On-line Work Management. Along with other corrective actions, the licensee completed the assessment in November 2020. During the 2022 PI&R readiness self-assessment, the licensee identified that the 2022 work order backlog biennial assessment had not been scheduled for 2022 (although it was required to be scheduled by December 31, 2021, and was due November 2022). Additionally, the licensee identified that the annual work order and work request backlog review had not been performed for 2021. This led the licensee to deem the corrective actions from the 2020 PI&R readiness self-assessment, ineffective. The licensee initiated additional corrective actions to further address the concerns (nuclear condition report 2431519).

4) Safety-Conscious Work Environment Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available. Based on interviews with plant staff and reviews of the latest safety culture survey results, the team found no evidence of challenges to a safety conscious work environment.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On November 17, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Tom Simril and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 2143837 2176144 2181760 2266064

Documents 2300974 2302626 2302634 2302706

2302707 2303887 2305356 2342017

2344352 2347098 2347364 2350950

2351187 2351615 2354956 2356199

2356298 2356772 2356974 2357189

2358529 2359785 2359991 2359993

2362709 2363667 2363831 2364311

2364647 2367070 2367367 2367381

2367457 2367459 2367784 2368553

2371723 2373019 2373374 2375740

2375813 2375996 2376022 2379984

2383078 2383228 2385280 2388798

2389432 2390261 2393718 2393733

2396503 2397351 2397949 2398462

2398745 2398921 2399490 2401326

2401560 2401927 2402459 2402479

2402590 2402710 2405297 2406502

2407902 2408205 2409314 2409746

2410295 2412065 2414079 2414669

2415834 2415837 2415847 2416012

2416660 2418051 2418833 2419020

2419447 2419894 2419921 2420233

21239 2421877 2422817 2423905

23924 2424201 2424572 2425057

25058 2425552 2425952 2426694

26696 2426981 2427097 2427164

27166 2427202 2427313 2427521

27709 2428747 2428876 2429628

29958 2430385 2430551 2431369

2431604 2431876 2432589 2433334

2434704 2435040 2436428 2437364

Inspection Type Designation Description or Title Revision or

Procedure Date

2438983 2439872 2440019 2441971

2442864 2446617 2446695 2446709

2449795

Procedures AD-EG-PWR-1611 Boric Acid Corrosion Control Program - Implementation 5

AD-MN-ALL-0005 Nuclear Planning 27

AD-MN-ALL-0006 Fluid Leak Management 3

AD-PI-ALL-0100 Corrective Action Program 27

AD-PI-ALL-0106 Cause Investigation Checklists 7

AD-PI-ALL-0300 Self Assessment and Benchmark Programs 5

AD-PI-ALL-0400 Operating Experience Program

AD-RP-All-5004 Vendor Cask Manuals 3

AD-SY-ALL-0150 Reporting Safeguards, Security, and Fitness for Duty Events 6

AD-WC-ALL-0200 On-line Work Management 20

AD-WC-ALL-0210 Work Request Initiation, Screening, Prioritization, and 15

Classification

PD-EG-PWR-1611 Boric Acid Corrosion Control Program 2

PY-NO-ALL-0200 Safety Conscious Work Environment 3

Work Orders 20185290 20185319 20200107 20205433

207878 20209822 20217938 20218885

218957 20221948 20224290 20224292

224775 20224800 20227008 20232203

235665 20235730 20235752 20235764

20433802 20437028 20454103 20454285

20454439 20455267 20458094 20462695

20468790 20469906 20475234 20475243

20475246 20484562 20499660 20503389

20503499 20519244 20526623 20531056

20534464 20559079 20431816 20434005

20454439 20459965 20485842 20495382

20499660 20503389 20531056 20534464

71152 Corrective Action 2449795

Documents

Resulting from

Inspection

Inspection Type Designation Description or Title Revision or

Procedure Date

71153 Corrective Action 2424761

Documents

8