IR 05000445/2013008

IR 05000445-13-008 and 05000446-13-008; on 10/28/2013 - 11/07/2013; Comanche Peak Nuclear Power Plant, Units 1 and 2, Problem Identification and Resolution (Biennial)

ML13358A242
Person / Time
Site:	Comanche Peak
Issue date:	12/24/2013
From:	Ray Kellar Division of Reactor Safety IV
To:	Flores R Luminant Generation Co
References
IR-13-008
Download: ML13358A242 (32)

Text

December 24, 2013

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000445/2013008 AND 05000446/2013008

Dear Mr. Flores:

On November 7, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On November 7, 2013, the NRC inspection team discussed the results of this inspection with Mr. K. Peters, Site Vice President, and other members of your staff. On November 20, 2013, the inspection team lead discussed an update to the inspection results with Mr. T. Hope, Nuclear Licensing Manager.

Based on the inspection sample, the inspection team determined that Comanche Peaks corrective action program, and your staffs implementation of the corrective action program, were adequate to support 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. 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 in which your employees are willing to raise nuclear safety concerns through at least one of the several means available.

UNITED STATES NUCLEAR REGULATORY COMMISSION RE G IO N I V 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 The NRC documented three findings of very low safety significance (Green) in this report. Two of these findings involved violations of NRC requirements. In addition, two licensee-identified violations of very low safety significance are listed in this report. The NRC is treating the violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or their significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's 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/

Ray L. Kellar, P.E., Chief Technical Support Branch Division of Reactor Safety

Docket Nos.: 50-445 and 50-446 License Nos.: NPF-87 and NPF-89

Enclosure:

Inspection Report 05000445/2013008 and 05000446/2013008 w/Attachments:

1. Supplemental Information 2. Information Request 3. Supplemental Information Request

cc w/Enclosure:

Electronic Distribution for Comanche Peak Nuclear Power Plant

SUMMARY

IR 05000445/2013008 and 05000446/2013008; 10/28/2013 - 11/07/2013; Comanche Peak

Nuclear Power Plant, Units 1 and 2, Problem Identification and Resolution (Biennial)

The inspection activities described in this report were performed by three inspectors from the NRCs Region IV office and the resident inspector at Comanche Peak Nuclear Power Plant.

The report documents three findings of very low safety significance (Green). Two of these findings involved violations of NRC requirements. Additionally, the report lists two licensee-identified violations of very low safety significance. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Assessment of Problem Identification and Resolution

Based on its inspection sample, the team concluded that the licensee maintained a corrective action program in which individuals generally identified issues at an appropriately low threshold.

Once entered into the corrective action program, the licensee generally evaluated and addressed these issues appropriately and timely, commensurate with their safety significance.

The licensees corrective actions were generally effective, addressing the causes and extents of condition of problems.

The licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the corrective action program. The licensee incorporated industry and internal operating experience in its root cause and apparent cause evaluations.

The licensee performed effective and self-critical nuclear oversight audits and self-assessments.

The licensee maintained an effective process to ensure significant findings from these audits and self-assessments were addressed.

The licensee maintained a safety-conscious work environment in which personnel were willing to raise nuclear safety concerns without fear of retaliation.

Cornerstone: Mitigating Systems

Green.

The team identified a Green finding for a failure to follow procedures that required the licensee to perform cause evaluations for maintenance preventable functional failures (MPFFs). Two MPFFs were not evaluated for their causes because a condition report was not generated to perform the evaluation. After identification of this performance deficiency, the licensee generated condition reports to evaluate the two MPFFs for causes.

The licensees failure to ensure that cause evaluations were performed for MPFFs as required by procedure was a performance deficiency. This constituted a programmatic weakness in the licensees maintenance rule program and corrective action program and resulted in MPFFs not being prioritized and evaluated appropriately for corrective action, which could result in recurring failures. The affected systems crossed the Initiating Events,

Mitigating Systems, and Emergency Preparedness cornerstones, but because the performance deficiency was associated with a programmatic weakness of the maintenance rule program, the inspectors determined that the Mitigating Systems cornerstone was the most affected. The finding was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At Power, the finding was determined to be of very low safety significance (Green)because the finding was not a deficiency affecting the design or qualification of a mitigating SSC, and did not represent a loss of system or function. The finding has a human performance cross-cutting aspect associated with work practices in that licensee supervision failed to define expectations regarding compliance with the maintenance rule and corrective action program procedures (H.4(b)). (Section 4OA2.5.a)

• The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, for the licensees failure to provide adequate acceptance criteria for bearing oil level in its residual heat removal pump motors. The team identified two examples of this violation, one of which resulted in pump bearing oil being low-out-of-specification. After identification of this performance deficiency, operations management issued an Operations Shift Order to ensure equipment operators appropriately verified bearing oil levels.

The failure to provide adequate acceptance criteria for an activity affecting quality was a performance deficiency. The performance deficiency was more than minor because it adversely affected the human performance attribute of the mitigating systems cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a safety-related system or train. The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated (P.1(a)). (Section 4OA2.5.b)

• The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III,

Design Control, for the licensees failure to control deviations from quality standards. After identifying that maintenance personnel had failed to ensure that subcomponents of 480-volt switchgear were properly identified and controlled during refurbishment, the licensee failed to document or evaluate where subcomponents of an indeterminate pedigree had been installed in safety-related applications. The licensee took immediate action to confirm the operability of the installed trip units and to determine the scope of the problem.

The failure to control deviations from quality standards as required by 10 CFR 50, Appendix B, Criterion III was a performance deficiency. This performance deficiency was more than minor because it affected the design control attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of components that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a safety-related system or train. The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated (P.1(a)).

(Section 4OA2.5.c)

Licensee-Identified Violations

The inspectors reviewed two violations of very low safety significance that the licensee had identified. Corrective actions taken or planned by the licensee have been documented in the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on a sample of corrective action documents that were open during the assessment period, which ranged from July 28, 2011, to the end of the on-site portion of this inspection on November 7, 2013.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 300 condition reports (CRs), including associated root cause analyses and apparent cause evaluations, from approximately 31,000 that the licensee had initiated or closed between July 28, 2011, and November 7, 2013. The majority of these (approximately 30,000) were lower-level condition reports that did not require cause evaluations. The inspection sample focused on higher-significance condition reports for which the licensee evaluated and took actions to address the cause of the condition.1 In performing its review, the team evaluated whether the licensee had properly identified, characterized, and entered issues into the corrective action program, and whether the licensee had appropriately evaluated and resolved the issues in accordance with established programs, processes, and procedures. The team also reviewed these programs, processes, and procedures to determine if any issues existed that may impair their effectiveness.

The team reviewed a sample of performance metrics, system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the licensees corrective action program. The team evaluated the licensees efforts in determining the scope of problems by reviewing selected logs, work orders, self-assessment results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed daily CRs and attended the licensees Station Ownership Committee and Management Review Committee meetings to assess the reporting threshold and prioritization efforts, and to observe the corrective action programs interfaces with the operability assessment and work control processes. The teams review included an evaluation of whether the licensee considered the full extent of cause and extent of condition for problems, as well as a review of how the licensee assessed generic implications and

1 The licensee assigns one of five significance levels to condition reports in its corrective action program:

A for significant conditions adverse to quality and other conditions adverse to quality that require root cause analyses; B-high-tier or B-low-tier for conditions adverse to quality that require apparent cause evaluations; C for conditions adverse to quality that do not require cause determinations; and D for conditions not adverse to quality. The team reviewed 18 of approximately 18 A-level CRs (100%), 21 of approximately 62 B-HT CRs (34%), 124 of approximately 769 B-LT CRs (16%), and 142 of the approximately 30,000 C-and D-level CRs (<1%).

previous occurrences of issues. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of problems similar to those the licensee had previously addressed. The team conducted interviews with plant personnel to identify other processes that may exist where problems could be identified and addressed outside the corrective action program.

The team reviewed corrective action documents that addressed past NRC-identified violations to evaluate whether corrective actions addressed the issues described in the inspection reports. The team reviewed a sample of corrective actions closed to other corrective action documents to ensure that the ultimate corrective actions remained appropriate and timely. The team reviewed a sample of 30 condition reports where the licensee had changed the significance level after initial classification to determine whether the level changes were in accordance with station procedure and that the conditions were appropriately addressed.

The team considered risk insights from both the NRCs and Comanche Peak Nuclear Power Plants risk models to focus the sample selection and plant tours on risk-significant systems and components. The team focused a portion of its sample on the component cooling water system, which the team selected for a five-year in-depth review. The team conducted walk-downs of this system and other plant areas to assess whether licensee personnel identified problems at a low threshold and entered them into the corrective action program.

b. Assessments

1. Effectiveness of Problem Identification

During the 28-month inspection period, licensee staff generated approximately 31,000 condition reports. The team determined that most conditions that required generation of a condition report by STA-421, Initiation of Condition Reports, had been appropriately entered into the corrective action program. However, the team noted several examples where the licensee had failed to properly identify conditions in accordance with procedures:

• On September 12, 2011, the NRC issued the 2011 problem identification and resolution inspection report (2011006). The inspection team had identified three examples of ineffective problem identification. The licensee had failed to document identification failure in its corrective action program. This was a minor performance deficiency not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee documented this observation in CR-2013-011130.

• The resident inspectors identified two instances of the licensees failure to update the equipment-out-of-service system in the Unit 2 control room on October 4, 2013, and October 7, 2013. The licensee failed to initiate a condition report documenting this condition until control room personnel were questioned by the resident inspector. This was a minor performance deficiency not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee documented the inspectors observation in CR-2013-010309.

• In 2012, the licensee identified its failure to properly control safety-related subcomponents of 480V circuit breakers during maintenance, as discussed in Section 4OA7, below. The licensee took corrective actions to ensure proper control of these components during future maintenance, but failed to completely and accurately identify which safety-related circuit breakers had been reinstalled in the plant with subcomponents of indeterminate quality.

This is further discussed in Section 4OA5.5.c below.

• On October 29, 2013, the team identified a low oil level in a residual heat removal pump motor bearing. An operator had observed the oil level earlier in the same shift but failed to identify the out-of-specification condition.

Additionally, the team identified a second residual heat removal pump that had no discernible acceptance criteria for motor bearing oil level. This is further discussed in Section 4OA5.5.b below.

STA-421, Revision 19, provides an extensive list of examples of conditions that either shall or should be documented in a condition report. The team noted that several items identified in the should list, if not documented in a condition report, may result in conditions adverse to quality not being promptly identified and corrected. Should items included conditions involving potential hazards to nuclear safety, radioactive releases, and violations of technical specification limits. While the potential existed to not document several items correctly in the condition reporting system based on the should list, the team did not find any examples where a condition had occurred and the licensee had not initiated a condition report.

Overall, the team concluded that the licensee generally maintained a low threshold for the formal identification of problems and entry into the corrective action program for evaluation. Licensee personnel initiated over 1,000 CRs per month during the inspection period. Most of the personnel interviewed by the team understood the requirements for condition report initiation; most expressed a willingness to enter newly identified issues into the corrective action program at a very low threshold.

However, some personnel indicated that they may not always initiate new condition reports for conditions that had been previously addressed in the corrective action program that they believed had been inadequately corrected.

2. Effectiveness of Prioritization and Evaluation of Issues

The sample of CRs reviewed by the team focused primarily on issues screened by the licensee as having higher-level significance, including those that received cause evaluations, those classified as significant conditions adverse to quality, and those that required engineering evaluations. The team also reviewed a number of condition reports that included or should have included immediate operability determinations to assess the quality, timeliness, and prioritization of these determinations.

The team concluded that the licensee had a strong screening process that effectively prioritized conditions identified in the corrective action program. Screening by the Station Ownership Committee, review by the Management Review Committee, and, when required, oversight of condition evaluations and corrective actions by the Corrective Action Review Board resulted in condition reports being appropriately screened by the proper organizational level.

Generally when a condition report significance was changed, the individual or group that made the change documented a justification. However, the team noted that changes made by the Management Review Committee did not include such an explanation. The licensee considers the MRC review part of the initial classification process and that such changes are permitted by procedure, but the team noted that an explanation for deviation from documented criteria would improve the quality of the classification process.

Despite the licensees strong initial screening process, the team identified two examples of weaknesses in interfacing screening processes:

• The licensees Cause Analysis Handbook included a process for assessing the risk of not taking corrective actions for the extent of condition. The team observed that the assessment criteria were subjective and may contribute to the occurrence of additional problems. As an example, the assessment criteria were applied incorrectly to the root cause analysis of CR-2013-000264. In this analysis, the consequence was incorrectly assessed as negligible versus marginal. The assessment process introduces the potential to justify not addressing the cause(s) associated with the extent of condition for significant conditions adverse to quality.

The licensee documented this observation in CR-2013-011487.

• The licensee has no procedural guidance to minimize the backlog and delay of screening conditions and events for potential maintenance rule functional failures. The corrective action program does not track completion of the screening, and the maintenance rule program has no timeliness requirement and no management review of incomplete screenings. The team noted that this could lead to the potential failure to identify systems that exceed their performance criteria. Specific examples are discussed in Section 4OA5.5.a below. The licensee documented this observation in CR-2013-011482.

Overall, the team determined that the licensees process for screening and prioritizing issues that had been entered into the corrective action program was adequate to support nuclear safety. Overall, operability determinations were consistent, accurately documented, and completed in accordance with procedures.

3. Effectiveness of Corrective Actions

In general, the corrective actions identified by the licensee to address adverse conditions were effective. The team noted a number of instances in which corrective actions had been untimely or incompletely accomplished, though in many cases the licensee self-identified these deficiencies through its self-assessment and auditing processes or by the licensees Corrective Action Review Board:

• On April 5, 2010, the licensee initiated Condition Report CR-2010-003305 to document a significant condition adverse to quality where Diesel Generator 2-02 failed to transfer from the droop mode to the isochronous mode during a surveillance test. The licensee performed a root cause analysis and took corrective actions to prevent recurrence. On July 7, 2011, the licensee initiated Condition Report CR-2011-007683 to document that the corrective actions taken in response to Condition Report CR-2010-003305 were ineffective in preventing recurrence of this significance condition adverse to quality. The NRC documented this issue in Inspection Report No. 2013002 (ML13123A139).

• On November 13, 2011, the licensee initiated Condition Report CR-2011-012827 to document an adverse trend when that the Clearance Index performance indicator turned yellow at the end of October 2011. The licensee classified this as a condition adverse to quality, performed an apparent cause evaluation (high-tier), and developed corrective actions. On May 2, 2013, the licensee initiated Condition Report CR-2013-005085 to document that the actions taken to reverse the adverse trend were ineffectivethe current trend included four Level 1 clearance events.

• On September 13, 2012, the licensee initiated CR-2012-009172, identifying two work orders that had not been evaluated for FSAR updates as required.

One of the work orders required an FSAR update; the modification had been in the plant for more than 5,000 days. The licensee corrected the issue by updating the FSAR under CR-2012-009307.

• On April 16, 2013, an Apparent Cause Evaluation was completed for CR-2013-003163 with no corrective actions identified to correct the apparent cause. The apparent cause was not clearly stated and no risk assessment of not correcting the apparent cause was included in the evaluation as required by procedure. The team determined that his performance deficiency was minor and was not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee documented this performance deficiency in CR-2103-011170.

Following its review of a sample of corrective actions implemented to correct NRC non-cited violations and findings documented since the last problem identification and resolution inspection, the team concluded that these actions had generally been timely and effective.

Overall, the team concluded that the licensee generally identified effective corrective actions for the problems evaluated in the corrective action program. The licensee generally implemented corrective actions in a timely manner, commensurate with their safety significance, and reviewed the effectiveness of the corrective actions appropriately.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensees program for reviewing industry operating experience, including reviewing the governing procedures. The team reviewed a sample of 15 industry operating experience communications and the associated site evaluations to assess whether the licensee had appropriately assessed the communications for relevance to the facility. The team also reviewed assigned actions to determine whether they were appropriate. The team reviewed one high tier apparent cause evaluation related to issues identified by an industry group regarding the evaluation of industry operating experience to ensure that the licensee had taken corrective actions to resolve the issues with the program.

b. Assessment

Overall, the team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. Some weaknesses, including inconsistency of evaluation, were noted during the beginning of the inspection period.

However, the team noted that after identification of this issue by an industry evaluation team in June 2012 (CR-2012-005821) the licensee had corrected these weaknesses.

Specifically, review and evaluation of operating experience has become more prescriptive. Licensee management reviews all NRC ENs and INPO OE items from the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the daily plan-of-the-day meeting. The licensees Industry Operating Experience Review Committee reviews all operating experience information at its weekly meeting to determine applicability and significance, and distribute to applicable work groups. The licensee also grades work groups evaluations of operating experience items in these meetings to ensure adequacy and consistency.

The team further determined that the licensee appropriately evaluated industry operating experience when performing root cause analysis and apparent cause evaluations. The licensee appropriately incorporated both internal and external operating experience into lessons learned for training and pre-job briefs.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of licensee self-assessments and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. The specific self-assessment documents and audits reviewed are listed in Attachment 1.

b. Assessment

Overall, the team concluded that the licensee had an effective self-assessment and audit process. Licensee management was involved with developing tactical self-assessments.

The team determined self-assessments were self-critical and thorough enough to identify deficiencies. Strategic self-assessments included personnel from outside organizations and tactical self-assessments received division management overview.

The team noted that the licensee conducted supplemental and follow-up audits when determined to be necessary. The team noted that the licensees Nuclear Oversight organization (NOS) prepared periodic reports assessing the overall health of departmental areas, but did not trend performance for areas that were not included in INPO guidance, specifically the areas of emergency preparedness and security. The team also noted that management focus areas for NOS appeared to be selected using subjective criteria.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The team interviewed forty-four individuals in five focus groups. The purpose of these interviews was

(1) to evaluate the willingness of licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method,

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and

(3) to evaluate the licensees safety-conscious work environment (SCWE). The focus group participants included personnel from Maintenance, Operations, Work Management, Radiation Protection, Engineering, Performance Improvement, Training, and Security. At the teams request, the licensees regulatory affairs staff selected the participants blindly from these work groups, based partially on availability. To supplement these focus group discussions, the team interviewed the SafeTeam manager2 to assess his perception of the site employees willingness to raise nuclear safety concerns and reviewed the SafeTeam case log. The team also reviewed the minutes from the licensees most recent safety culture monitoring panel meetings.

b. Assessment

1. Willingness to Raise Nuclear Safety Issues

All individuals interviewed indicated that they would raise nuclear safety concerns.

All felt that their management was receptive to nuclear safety concerns and was willing to address them promptly. All of the interviewees further stated that if they were not satisfied with the response from their immediate supervisor, they had the ability to escalate the concern to a higher organizational level. Most expressed positive experiences after raising issues to their supervisors. All expressed positive experiences documenting most issues in condition reports, though some noted that it was sometimes difficult to determine how issues had been resolved.

2 SafeTeam is the licensees employee concerns program.

2. Employee Concerns Program

All interviewees were aware of SafeTeam. Most explained that they had heard about the program through various means, such as posters, training, presentations, and discussion by supervisors or management at meetings. All interviewees stated that they would use SafeTeam if they felt it was necessary. All but one individual expressed confidence that their confidentiality would be maintained if they brought issues to SafeTeam. Several noted that they had been interviewed during SafeTeam investigations; they stated that questions by the individuals performing the investigation maintained the confidentiality of the process.

3. Preventing or Mitigating Perceptions of Retaliation

When asked if there have been any instances where individuals experienced retaliation or other negative reaction for raising issues, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation, harassment, intimidation or discrimination at the site.

.5 Findings

a. Failure to Perform Cause Evaluations for Maintenance-Preventable Functional Failures

Introduction.

The team identified a Green finding for a failure to follow procedures that required the licensee to perform cause evaluations for maintenance preventable functional failures (MPFFs). Two MPFFs were not evaluated for their causes because a condition report was not generated to perform the evaluation.

Description.

On February 6, 2012, a functional failure of the plant computer occurred and was documented under CR-2012-001233. This failure was later determined to be a MPFF under the licensees maintenance rule program. On February 4, 2013, a functional failure of instrument air dryer 2-01 occurred and was documented under CR-2013-001186. This failure was also determined to be a MPFF under the licensees maintenance rule program.

Licensee procedure STA-744, Maintenance Effectiveness Monitoring Program, requires that the licensee perform a cause analysis for each MPFF, and that corrective actions be identified and implemented. The procedure further specifies that the System Engineering department shall ensure that MPFFs are documented on a Condition Report and that the organization assigned the Condition Report shall ensure a cause analysis is performed, but does not identify individual responsibilities. In practice, only the system engineer responsible for the affected system and the maintenance rule coordinator know when the MPFF is screened. There is no other process in either the corrective action program or the maintenance rule program to ensure that every MPFF is ultimately evaluated for causes.

The licensees corrective action program allows conditions that are potential MPFFs to be screened initially at a lower level, and then later upgraded to a low-tier apparent cause evaluation (B-LT) once the failure has been confirmed to be an MPFF. However, the licensee has no timeliness requirement for screening potential MPFFs and does not track the screening as a required action in its corrective action program. As a result, these lower level condition reports may be closed prior to screening the failures. In these cases, the procedures require a new condition report to be generated to perform the required cause evaluation.

The team identified that of 16 MPFFs identified over the previous two years, six did not have cause evaluations performed under the initial condition report. Of those six, four had cause evaluations performed under subsequent condition reports. The two failures identified above did not. The inspectors determined based on the frequency of occurrence and the lack of sufficient checks and clear expectations that these failures to follow procedures were not isolated and indicated a programmatic weakness. The licensee generated two condition reports, CR-2013-011135 and CR-2013-011450, to perform the required cause evaluations, and a third report, CR-2013-011483, to address the failure to follow procedures.

Analysis.

The licensees failure to ensure that cause evaluations were performed for MPFFs as required by procedure was a performance deficiency. This constituted a programmatic weakness in the licensees maintenance rule program and corrective action program and resulted in MPFFs not being prioritized and evaluated appropriately for corrective action, which could result in recurring failures. The affected systems crossed the Initiating Events, Mitigating Systems, and Emergency Preparedness cornerstones, but because the performance deficiency was associated with a programmatic weakness of the maintenance rule program, the inspectors determined that the Mitigating Systems cornerstone was the most affected. The finding was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At Power, the finding was determined to be of very low safety significance (Green)because the finding was not a deficiency affecting the design or qualification of a mitigating SSC, and did not represent a loss of system or function. The finding has a human performance cross-cutting aspect associated with work practices in that licensee supervision failed to define expectations regarding compliance with the maintenance rule and corrective action program procedures (H.4(b)).

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The licensee documented the finding in the corrective action program as CR-2013-011483 and generated condition reports to evaluate the two MPFFs for cause. Because the finding does not involve a violation and is of very low safety significance (Green), it is being characterized as a finding:

FIN 05000445/2013008-01 and 05000446/2013008-01, Failure to Perform Cause Evaluations for Maintenance Preventable Functional Failures.

b. Failure to Provide Adequate Acceptance Criteria

Introduction.

The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to provide adequate acceptance criteria for bearing oil level in its residual heat removal pump motors. The team identified two examples of this violation, one of which resulted in pump bearing oil being low-out-of-specification.

Description.

On October 29, 2013, during a plant tour, the team identified that the lower motor bearing oil level in Residual Heat Removal Pump 2-02 appeared to be below the specified band. A placard adjacent to the sight glass stated that acceptable oil level was between inch above and inch below a line marked on the sight glass. When the team identified the out-of-specification condition, the oil level was inch below the mark. After the team brought this to the attention of the control room, an operator confirmed that the oil level was low out of specification and restored the oil level to within the required band. The licensee documented this issue in CR-2013-011067.

Operations management noted that an operator had observed the bearing oil level earlier in the same shift, but failed to identify the low-out-of-specification condition due to difficulty in viewing the oil level in the sight glass from the ground.

The licensee stated that the +/--inch specification was based on vendor recommendations, but the minimum oil level for operability was 3 inches above the motor flange. The as-found condition of inch below the sight glass mark corresponded to 31/2 inches above the pump motor flange. Thus, RHR Pump 2B remained operable.

After identifying the low oil level on RHR Pump 2-02, the team reviewed the condition of the other three RHR pumps. No placard was provided for RHR Pump 1-01, whose motor had been replaced during refueling outage 1RF16 in the spring of 2013. Further, the team noted that there were three marks on the lower bearing oil level sight glass for the RHR Pump 1-01 motor; it was not clear which of these marks indicated the acceptable standby oil level. This condition had existed since the motor had been replaced approximately six months prior to identification by the team. After further investigation, the licensee determined that the bearing oil level on RHR Pump 1-01 was within the specified band, despite the lack of clear indication. The licensee documented this condition in CR-2013-011336 and CR-2013-011393.

Prior to the teams identification of the Pump 1-01 condition, the licensee had initiated CR-2013-011094, identifying potential enhancements to oil level indications on the RHR pump motors. Though this CR noted the missing placard on Pump 1-01, it had been identified as an enhancement. It was classified as Condition Level D: Not a Condition Adverse to Quality.

Analysis.

The failure to provide adequate acceptance criteria for an activity affecting quality was a performance deficiency. The performance deficiency was more than minor because it adversely affected the human performance attribute of the mitigating systems cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a safety-related system or train. The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated (P.1(a)).

Enforcement.

Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part that instructions, procedures, and drawings shall contain appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to this requirement, prior to November 7, 2013, the licensee failed to provide instructions, procedures, and drawings with appropriate acceptance criteria for determining that an important activity had been satisfactorily accomplished. Specifically, the licensee failed to provide operators with acceptance criteria to ensure residual heat removal pump motor bearing oil levels were within the specified band. After identification of this performance deficiency, operations management issued an Operations Shift Order to ensure equipment operators appropriately verified bearing oil levels. Because this violation was of very low safety significance (Green) and was entered into the licensees corrective action program as CR-2013-011067, -011094, -011336, and -011393, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRCs Enforcement Manual:

NCV 05000445/2013008-02 and 05000446/2013008-02, Failure to Provide Adequate Acceptance Criteria.

c. Components of Indeterminate Quality Installed in Safety-Related Applications

Introduction.

The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to control deviations from quality standards. After identifying that maintenance personnel had failed to ensure that subcomponents of 480-volt switchgear were properly identified and controlled during refurbishment, the licensee failed to document or evaluate where subcomponents of an indeterminate pedigree had been installed in safety-related applications.

Description.

In 2009, after beginning a refurbishment campaign for all safety-related and non-safety-related 480-volt switchgear, the licensee identified that during its previous refurbishment campaign maintenance personnel had failed to establish appropriate material control procedures to ensure traceability of Amptector trip units installed in safety-related applications. These Amptector trip units provide a required overcurrent trip function. As a result of the lack of procedures to ensure traceability, an unknown number of trip units of indeterminate quality had been installed in safety-related applications. In 2012, the licensee changed its process to ensure traceability of components for future refurbishments, but failed to identify and control existing deviations from quality standards for breakers installed in the plant.

As of November 7, 2013, the licensee had a total of 115 safety-related 480-volt breakers on-site. Ninety-seven of these were installed in the plant; 89 had Amptector trip units installed. (The eight reactor trip breakers were installed without Amptectors.) Forty of the 89 were confirmed to have safety-related trip units with confirmed pedigree. Thirteen additional were scheduled to be refurbished between December 2013 and April 2014.

The licensee could not confirm the quality pedigree of the trip units installed in the remaining 36 breakers. As of the completion of the on-site inspection activities, the licensee continued to research the traceability of these components and planned to review the schedule for refurbishment or Amptector replacement.

Because each breaker passed its preinstallation bench tests and none had failed in service, the licensee determined that it had reasonable assurance that all installed breakers would perform their safety functions. The licensees failure to establish measures for identification and control of Amptector trip units prior to 2012 was identified by the licensee and is documented in Section 4OA7 below.

Analysis.

The failure to control deviations from quality standards as required by 10 CFR 50, Appendix B, Criterion III was a performance deficiency. This performance deficiency was more than minor because it affected the design control attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of components that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a safety-related system or train. The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated (P.1(a)).

Enforcement.

Title 10 CFR 50, Appendix B, Criterion III, requires in part that the licensee shall establish provisions to assure that appropriate quality standards are specified and that deviations from such standards are controlled. Contrary to this requirement, prior to November 5, 2013, the licensee failed to establish provisions to assure that deviations from specified quality standards were controlled. Specifically, the licensee failed to establish provisions to control the installation of subcomponents of indeterminate quality into safety-related 480-volt switchgear. As a result, an unknown number of 480-volt breakers with trip units of indeterminate quality were installed in safety-related applications. The licensee took immediate action to confirm the operability of the installed trip units and to determine the scope of the problem. Because this violation was of very low safety significance (Green) and was entered into the licensees corrective action program as CR-2013-011405, it is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRCs Enforcement Manual:

NCV 05000445/2013008-03 and 05000446/2013008-03, Components of Indeterminate Quality Installed in Safety-Related Applications.

4OA6 Meetings

Exit Meeting Summary

On November 7, 2013, the team presented the inspection results to Mr. K. Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information that the team reviewed had been returned or destroyed. On November 20, 2013, the inspection team lead discussed an update to the inspection results with Mr. T. Hope, Nuclear Licensing Manager.

4OA7 Licensee-Identified Violations

The following two violations of very low safety significance (Green) were self-identified by the licensee. These violations of NRC requirements meet the criteria of section 2.3.2.a of the NRC Enforcement Policy for disposition as non-cited violations.

• Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected. Contrary to this requirement, the licensee failed to promptly identify and correct the continued unreliability of its service water vacuum breakers. The licensee initially identified and documented this violation in CR-2011-007644 and CR-2011-08500. This violation was of very low safety significance because it did not result in the loss of operability or functionality of any system or train.

• Title 10 CFR 50, Appendix B, Criterion VII, Identification and Control of Materials, Parts, and Components, requires that measures shall be established for the identification and control of materials, parts, and components. Contrary to this requirement, the licensee failed to establish measures to identify and control safety-related Amptector trip units. The licensee identified and documented this violation in CR-2009-001000. This violation was of very low safety significance because it did not result in the loss of operability or functionality of any system or train.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Ambrose, Corrective Action Program Manager

J. Bain, Equipment Reliability Supervisor

T. Gibbs, Safeteam Manager

T. Hope, Nuclear Licensing Manager

B. Mays, Vice President, Engineering

G. Merka, Regulatory Affairs

B. St. Louis, Manager, Operations Support

B. Thompson, Corrective Action Program Supervisor

H. Winn, Corrective Action Program Manager

NRC Personnel

J. Kramer, Senior Resident Inspector

LIST OF ITEMS

Opened and Closed

05000445/2013008-01;

05000446/2013008-01 FIN Failure to Perform Cause Evaluations for Maintenance Preventable Functional Failures (Section 4OA2.5.a)

05000445/2013008-02;

05000446/2013008-02 NCV Failure to Provide Adequate Acceptance Criteria (Section 4OA2.5.b)

05000445/2013008-03;

05000446/2013008-03 NCV Components of Indeterminate Quality Installed in Safety-

Related Applications (Section 4OA2.5.c)