IR 05000483/2016008

NRC Problem Identification and Resolution Inspection Report 05000483/2016008

ML16126A558
Person / Time
Site:	Callaway
Issue date:	05/05/2016
From:	Thomas Hipschman Division of Reactor Safety IV
To:	Diya F Union Electric Co
References
IR 2016008
Download: ML16126A558 (26)

Text

SUBJECT:

CALLAWAY PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000483/2016008

Dear Mr. Diya:

On March 24, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Callaway Plant and discussed the results of this inspection with Mr. T. Herrmann, Site Vice President, and other members of your staff.

The inspection team documented the results of this inspection in the enclosed inspection report.

Based on the inspection sample, the inspection team determined that Callaways 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, 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.

The NRC inspectors did not identify any findings or violations of more than minor significance.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 Thomas R. Farnholtz Acting for/

Thomas R. Hipschman, Team Lead Inspection Program and Assessment Team Division of Reactor Safety Docket No. 50-483 License No. NPF-30

Enclosure:

Inspection Report 05000483/2016008 w/Attachments:

1. Supplemental Information 2. Information Request

REGION IV==

Docket: 05000483 License: NPF-30 Report: 05000483/2016008 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction of Highway CC and Highway O Fulton, MO Dates: February 29 through March 24, 2016 Team Lead: E. Uribe, Reactor Inspector Inspectors: H. Freeman, Senior Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector M. Langelier, P.E., Resident Inspector, Callaway Plant C. Franklin, General Engineer (Observer)

Approved By: T. Hipschman, Team Lead Inspection Program and Assessment Team Division of Reactor Safety-1- Enclosure

SUMMARY

IR 05000483/2016008; 02/29/2016 - 03/24/2016; Callaway Plant; Problem Identification and

Resolution (Biennial)

The inspection activities described in this report were performed between February 29 and March 24, 2016, by three inspectors from the NRCs Region IV office and the resident inspector at the Callaway Plant.

Assessment of Problem Identification and Resolution Based on the 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.

No findings were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on a sample of corrective action documents that were open and/or closed during the assessment period, which ranged from September 1, 2014, to the end of the on-site portion of this inspection on March 24, 2016.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 292 condition reports, also known as Callaway action requests, including associated root cause analyses and apparent cause evaluations, from 10,606 that the licensee had initiated or closed between September 1, 2014, and March 24, 2016. The inspection sample focused on higher-significance condition reports for which the licensee evaluated and took actions to address the cause of the condition.

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 action requests and attended the licensees screening, corrective action review board, and leadership 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 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 may 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 53 condition reports where the licensee had changed the significance level after initial classification to determine whether the level changes were in accordance with station procedures and that the conditions were appropriately addressed.

The team considered risk insights from both the NRCs and Callaways risk models to focus the sample selection and plant tours on risk-significant systems and components.

The team focused a portion of its samples on the essential service water system, the emergency diesel generator heating ventilation and air conditioning system, and on components that had been reversed engineered, for a five-year in-depth review. The team conducted walk-downs of these systems 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 18-month inspection period, licensee staff generated approximately 10,000 condition reports. The team determined that most conditions that required generation of a condition report by Procedure APA-ZZ-00500, Corrective Action Program, and associated attachments, 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:

• An NRC Special Inspection Report 2015009 documented a non-cited violation for failure to identify and correct a condition adverse to quality. Specifically, as of September 23, 2015, the licensee had not taken corrective action, following a previous identification of undersized field current rectifier bridges on auxiliary feedwater flow control valve Modutronics cards, to ensure that an independent review of the modified circuit design had been completed or that the modified cards had been subjected to a sufficient testing and qualification program. Thus, following questioning by the NRC, the licensee identified additional components (two other rectifier bridges) on the newly modified circuit cards that were also potentially undersized.

• The team identified that Callaway Action Request 201405750 documented an equipment issue regarding control building cooling, but originally addressed the issue a number of days before issuing the action request. The team communicated that, while it appears that the site had initiated actions to evaluate the equipment issue, the condition should have be documented in an action request on the date of discovery. The action request was initiated on August 29, 2014, but should have the date of August 24, 2014.

• While reviewing the activities performed by the employee concerns program during the assessment period, the inspectors identified an example where the program guidance allowed the delay of a potential technical concern entry into the corrective action program for over two weeks. Once entered into the corrective action program, the licensee concluded that the concern did not affect activities at the Callaway Plant. The employee concerns program manager had raised the question as to whether the issue should be entered into the corrective action program, but never received an adequate response, so she finally documented the issue on an action request.

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 550 action requests per month during the inspection period. Most of the personnel interviewed by the team understood the requirements for condition report initiation and most expressed a willingness to enter newly identified issues into the corrective action program at a very low threshold.

2. Effectiveness of Prioritization and Evaluation of Issues

The sample of action requests 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 identified several examples where the licensee failed to address aspects of issue evaluation in accordance with their process:

• The team identified a number of instances of approvals for extending due dates while action requests were in Pending Close status.

Procedure APA-ZZ-00500, Corrective Action Program, does not contain guidance for performing that kind of activity. The site initiated Callaway Action Request 201601916 documenting this deficiency.

• The team identified that several management evaluation/closure reviews were not in accordance with procedural guidance. Specifically, when answering No to any question, justification did not always exist. In addition, a number of questions required either a Yes or a No, yet an N/A was the answer, without an adequate justification. The site initiated Callaway Action Request 201601918 documenting this deficiency.

• The team identified that management closure reviews were not in accordance with procedural guidance. Specifically, the criteria for evaluating the completeness and adequacy of corrective actions attached to every Significance Level 1, 2, and 3 action request does not meet the templates specified in Procedure APA-ZZ-00500, Appendices 12, 13, and 14. The site initiated Callaway Action Request 201602445 documenting this deficiency.

• The team identified that the licensees process characterizes a condition based on a measure of severity and frequency. The measure of frequency has three levels. Level 3 is defined as not acceptable to occur in the life of an individual item, system, process, or should not reasonably be expected to occur in the life of a large number of similar components. The licensees process allows a classification of Significance Levels 4 and 5 of a condition characterized as a Level 3. The team determined that this introduces conflict because Significance Levels 4 and 5 are broke-fix items.

• The team reviewed a number of rescreened corrective action requests and identified that some did not provide justification for changing the significance levels. As an example, significance levels changed during the rescreening from one level to another, skipping levels (e.g., Significance Level 1 to Significance Level 4). It was not always clear why the condition described in an action request did not meet the levels between the original level and final level.

• The team identified that in Callaway Action Requests 201505796 and 201403898, corrective actions to prevent recurrence did not align with the identified root causes as expected. Although corrective actions were adequate, the corrective action listed did not provide the clarity required, but the team did conclude that corrective actions to prevent recurrence were implemented.

Overall, the team determined that the licensees process for prioritizing and evaluating issues that had been entered into the corrective action program supported nuclear safety. The licensees operability determinations were generally 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:

• The team communicated that it became apparent that, during our focus group meetings, a communication gap exists on change management, Although the site implemented corrective actions, it is not always clear to site employees why changes are made. It was evident that site personnel desire better communication as to the reasons for the changes. The site documented this observation in Callaway Action Request 201602454.

• The team identified that the use of the Why analysis method to address equipment issues was prohibited. Although the teams understanding of this is to exclude the use of the Why analysis as the only method, clarification is needed in Procedure APA-ZZ-00500, Appendix 12, Significant Adverse Condition - Significance Level 1. The site documented this observation in Callaway Action Request 201601936.

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 these 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 12 industry and NRC 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 the assigned actions to determine whether they were appropriate. The team reviewed four procedures governing the review and use of internal and external operating experience.

The team also reviewed 22 action requests (corrective action program entries) related to the use of operating experience in plant activities.

b. Assessment Overall, the team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. Operating experience information was incorporated into plant procedures and processes as appropriate.

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. The team determined that self-assessments were self-critical and thorough enough to identify deficiencies.

.4 Assessment of Safety-Conscious Work Environment

A safety-conscious work environment is defined by the NRC as an environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation. The NRC recognizes that an employees willingness to identify safety concerns can also be affected by other factors such as the effectiveness of the licensees processes for resolving concerns or senior managements ability to detect and prevent retaliatory actions. Therefore, the NRC assesses the safety-conscious work environment for indications that could impact employees willingness to raise safety concerns as part of the reactor oversight process.

a. Inspection Scope

The team interviewed 39 individuals in five focus groups and 6 individuals in one-on-one interviews. The purpose of these interviews was:

(1) to evaluate the willingness of the licensees staff to raise safety issues without fear of retaliation;

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

(3) to evaluate licensee managements involvement in establishing and promoting a safety-conscious work environment (SCWE). The focus group participants included personnel from system engineering, design engineering, electrical maintenance, mechanical maintenance, instrumentation and controls, nuclear oversight, and quality control. The licensees regulatory affairs staff assisted in coordinating the interviews from participants who were randomly selected based upon staff availability and position.

To supplement these focus group discussions, the team interviewed the employee concerns program manager to assess her perceptions of employees willingness to raise nuclear safety concerns. The team reviewed the employee concerns program case log and select case files.

b. Assessment 1. Willingness to Raise Nuclear Safety Issues All individuals interviewed indicated that they felt free to raise nuclear safety concerns without fear of retaliation. All indicated that management was receptive to nuclear safety concerns and was willing to address them accordingly. All interviewees stated that they had the ability to initiate action requests, but the maintenance groups generally relied on their supervisor to actually initiate and document the concern.

2. Perceived Effectiveness of the Corrective Action Program

Individuals from all groups indicated that they believed that the corrective action program was generally effective and appropriately prioritized. Some individuals expressed that they felt that too much emphasis was placed on low-level action requests, but none indicated that conditions adverse to quality were not being addressed. All of the interviewees agreed that if they were not satisfied with the initial response to their concern, they had the ability to escalate the concern to a higher organizational level; however, individuals from one group appeared reluctant to push resolution of a concern beyond the initial review level. Most expressed positive experiences after raising issues to their supervisors. Several individuals from different groups expressed positive experiences with using a new process called the technical conscience board, where they had the ability to elevate their concerns and perhaps influence the resources directed toward resolution of their concern.

3. Management Involvement in Establishing and Promoting a Safety-Conscious Work Environment Responses from the focus group interviewees indicate that they believe that management has established and promoted a safety-conscious work environment where individuals feel free to raise safety concerns without fear of retaliation.

Individuals stated that management encourages them to raise and document safety concerns in the corrective action program. None of the individuals had experienced retaliation or other negative reaction for raising issues. Individuals were aware of and generally expressed a positive view of the employee concerns program.

However, some individuals believed that the station still could improve communications down to the worker level associated with concerns, process changes, and decisions associated priorities. Overall, the team determined that the licensee had processes in place to promote a safety-conscious work environment that were generally effective.

.5 Findings

No findings were identified

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 24, 2016, the inspectors presented the inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

ATTACHMENTS:

1. Supplemental Information 2. Information Request

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Aldrich, Senior Performance Improvement Coordinator

M. Breshears, Engineer, HVAC Systems

M. Daly, Supervisor, Corrective Action Program

F. Diya, Senior Vice President and Chief Nuclear Officer

M. Hall, Director, Engineering Program

T. Herrmann, Site Vice President

A. Hunt, Engineer, Motors Program

S. Kovaleski, Director, Engineering Design

S. Maglio, Manager, Regulatory Affairs (Retiring)

S. McLaughlin, Manager Performance Improvement

J. McLaughlin, Engineer, Diesel Systems

S. Petzel, Engineer, Regulatory Affairs/Licensing

M. Waller, Manager, Employee Concerns

R. Wink, Manager, Regulatory Affairs (Incoming)

T. Witt, Engineer, Regulatory Affairs/Licensing

B. Price, Supervisor, Operations

NRC Personnel

S. Alferink, Reactor Inspector

T. Hartman, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

No docket items opened, closed, or discussed in this report.

Attachment 1