IR 05000424/2013008
| ML13086A488 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/27/2013 |
| From: | Hopper G Reactor Projects Branch 7 |
| To: | Tynan T Southern Nuclear Operating Co |
| References | |
| IR-13-008 | |
| Download: ML13086A488 (20) | |
Text
UNITED STATES rch 27, 2013
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000424/2013008 AND 05000425/2013008
Dear Mr. Tynan:
On February 14, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on February 14, 2013, with you and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and 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 Vogtle Electric Generating Plant Units 1 and 2 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.
No findings were identified during this inspection.
Enclosure 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 Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81
Enclosure:
VOGTLE ELECTRIC GENERATING PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000424/2013008 AND 05000425/2013008
REGION II==
Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report No.: 05000424/2013008 and 05000425/2013008 Licensee: Southern Nuclear Operating Company, Inc Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA Dates: January 28 - February 1, 2013 February 11 - 14, 2013 Inspectors: R. Rodriguez, Sr. Project Engineer, Team Leader R. Taylor, Sr. Project Inspector L. Lake, Sr. Reactor Inspector N. Pitoniak, Fuel Facility Inspector Approved by: G. Hopper, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000424/2013008, 05000425/2013008; January 28, 2013 - February 14, 2013; Vogtle
Electric Generating Plant, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by a senior project engineer, a senior project inspector, a senior reactor inspector, and a fuel facility inspector. 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.
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 the NRC and other external organizations 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. However, two minor performance deficiencies were identified, during the inspection, related to your prioritization and evaluation of identified problems and the adequacy of site procedures associated with the corrective actions to prevent recurrence.
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.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Assessment of the Corrective Action Program
- (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 February 2011 and January 2013, including a detailed review of selected CRs associated with the following risk-significant systems: Nuclear Service Cooling Water (NSCW), Residual Heat Removal (RHR), and Main Steam. 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 walkdowns were also performed to assess the Main Control Room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds 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 NMP-GM-002-006, Root Cause Analysis Instruction, and NMP-GM-002-007, Apparent Cause Determination Instruction. 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 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 screening meetings and Management Review Committee (MRC) meetings.
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 NMP-GM-002-001, Corrective Action Program, managements expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by inspectors 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 inspectors determined that system deficiencies were being identified and placed in the CAP.
Prioritization and Evaluation of Issues Based on the review of CRs sampled by the inspection team 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 severity level determination guidance in NMP-GM-002-001, Corrective Action Program. Each CR was assigned a severity level at the CAP coordinator (CAPCO) meeting, 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 procedures NMP-GM-002-006, and NMP-GM-002-007.
The inspectors identified one performance deficiency associated with the licensees prioritization and evaluation of issues. Specifically, the inspectors identified several instances where the licensees immediate determination of operability did not provide sufficient documented information to conclude that theres reasonable expectation that the component in question was operable. This was contrary to NMP-AD-012, Operability Determinations and Functionality Assessments. The licensee initiated CR 589738 to address this issue. However, because this performance deficiency did not adversely affect any ROP cornerstone objectives, the inspectors determined the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
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.
The inspectors identified one performance deficiency associated with procedural guidance related to designating corrective actions as CAPRs. Specifically, procedure NMP-GM-002-001 specifies that CAPRs are intended to address Root Causes.
However, this same procedure does not allow the designation of CAPRs for certain types of human performance, organizational and training related corrective actions. The inspectors reviewed several human performances, organizational and training related severity level 1 Root Causes which did not have corresponding CAPRs. Corrective actions were established to address these Root Causes but were not designated as CAPRs. However, because this performance deficiency did not adversely affect any ROP cornerstone objectives, and because the inspectors did not identify any instances where the corrective actions were not adequate, the inspectors determined the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this issue into their corrective action program as CR 581528.
- (3) Findings No findings of significance were identified.
b. Assessment of the Use of Operating Experience (OE)
- (1) Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure NMP-GM-008, Operating Experience Program, and reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors 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 February 2011, 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 operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators 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, operating experience was included in all root cause evaluations in accordance with licensee procedure NMP-GM-002-006.
- (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 NMP-GM-003, Self Assessment.
- (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 several on-site workers regarding their knowledge of the corrective action program at Vogtle 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 manager. Additionally, the inspectors 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.
- (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 February 14, 2013, the inspectors presented the inspection results to Mr. Tom Tynan 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:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- M. Carstensen, CAP Supervisor
- T. Mattson, Performance Improvement Sr. Engineer
G. Gunn Sr. Licensing Specialist
- T. Tynan, Vogtle Vice President
- J. March, Concerns Program Manager
- D. Puckett, Performance Improvement Supervisor
- M. Hickox, System Engineer
- I. Feliciano, System Engineer
- N. Howell, System Engineer
- F. Santiago, Program Engineer
- B. Coker, System Engineer
- D. Pittman, Level II NDE
- G. Fechter, ISI Engineer
NRC personnel
- M. Cain, Senior Resident Inspector
- T. Chandler, Resident Inspector
LIST OF REPORT ITEMS
Opened and Closed
None
Closed
None
Discussed
None