ML11229A777
| ML11229A777 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/17/2011 |
| From: | Ring M NRC/RGN-III/DRP/B1 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-11-008 | |
| Download: ML11229A777 (5) | |
See also: IR 05000461/2011008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
August 17, 2011
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
ERRATA TO CLINTON POWER STATION, UNIT 1, NRC PROBLEM
IDENTIFICATION AND RESOLUTION INSPECTION REPORT
Dear Mr. Pacilio:
On July 8, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Problem Identification
and Resolution Inspection Report 05000461/2011008 (ML11189A129). In the Inspection
Report, the alphanumeric identifier for the cross-cutting aspect for non-cited violation (NCV)05000461/2011008-02 was incorrect. Please replace pages 2 and 11 of Inspection Report 05000461/2011008 with the enclosed corrected pages.
We apologize for any inconvenience to you and your staff.
Sincerely,
/RA/
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Docket Nos. 50-461
License Nos. NPF-62
Enclosure:
Errata to Inspection Report 05000461/2011008
cc w/encl:
Distribution via ListServ
ERRATA TO INSPECTION REPORT 05000461/2011008
2
Enclosure
adversely affected the cornerstone objective of ensuring availability and reliability of
systems that respond to initiating events to prevent undesirable consequences.
This finding was of very low safety significance (Green) because the licensee was able
to demonstrate that the operability calls that were previously made relating to the second
level UV relays were still valid and acceptable. The inspectors concluded that this
finding affected the cross-cutting aspect of human performance. Specifically, the
licensee failed to use conservative assumptions in decision making related to immediate
operability determinations of conditions adverse to quality. [IMC 0310 H.1(b)
(Section 4OA2.1.b(2)(1))
Green
The inspectors determined the finding was more than minor because, if left
uncorrected, failure to maintain a quality record as evidence of an activity affecting
quality of safety-related equipment due to inappropriate disposition of CAs pertaining
to missing/lost quality records could become a more significant safety concern.
This finding was of very low safety significance because this finding did not represent an
actual loss of any safety function of the Mitigation Systems. The inspectors concluded
that this finding affected the cross-cutting aspect of human performance. Specifically,
the licensee did not ensure complete, accurate and up-to-date design documentation
and work packages. [IMC 0310 H.2(c) (Section 4OA2.1.b(2)(2))
. The inspectors identified a finding of very low safety significance with an
associated NCV of 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance
Records. Specifically, the licensee failed to maintain a quality record documenting a
nondestructive examination (NDE) of a safety-related spreader beam lifting device.
After losing the original NDE report, the licensees corrective action (CA) was to recreate
the report from memory and maintain the recreated report as the quality record.
Upon review and questioning from the NRC, the licensee was able to locate the missing
NDE report in the records archive. This issue was entered into the licensees CAP as
Cornerstone: Initiating Events
Green
The finding was of more than minor significance because it was similar to Example 4a in
IMC 0612, Power Inspection Reports, Appendix E, Examples of Minor Issues, in that,
the licensee routinely failed to perform EFR evaluations on similar CAs related to
significant conditions adverse to quality. The finding was a licensee performance
deficiency of very low safety significance due to answering no to all questions under the
Initiating Events Cornerstone column of IMC 0609 Attachment 4, Phase 1 - Initial
Screening and Characterization of Findings. The inspectors concluded that this finding
affected the cross-cutting aspect of problem identification and resolution. Specifically,
the licensee failed to thoroughly evaluate problems to include conducting EFRs of CAs
to ensure that problems were resolved. [IMC 0310 P.1(c) (Section 4OA2.1.b(3)(1))
. The inspectors identified a finding of very low safety significance with an
associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings. The licensee failed to perform an effectiveness review (EFR) to ensure that
CAs taken to prevent recurrence of a significant condition adverse to quality were
actually effective to preclude repetition. The licensee entered this violation into its CAP
as ARs 1221616, 1221661, and 1223806 to investigate the cause and to identify
appropriate CAs.
ERRATA TO INSPECTION REPORT 05000461/2011008
11
Enclosure
and Characterization of Findings, Table 4a for the Mitigation Systems Cornerstone.
Based on answering 'no' to each of the Phase 1 screening questions identified in the
Mitigation Systems Cornerstone column of Table 4a, the finding was determined to be of
very low safety significance. Specifically, this finding did not represent an actual loss of
any safety function of the Mitigation Systems.
This finding has a cross-cutting aspect in the area of Human Performance, Resources
because the licensee did not ensure complete, accurate and up-to-date design
documentation, procedures, and work packages, and correct labeling of components.
Cross-Cutting Aspects
Title 10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records, requires, in
part, that sufficient records shall be maintained to furnish evidence of activities affecting
quality. The records shall include at least the following: Operating logs and the results
of reviews, inspections, tests, audits, monitoring of work performance, and materials
analyses. The records shall also include closely-related data such as qualifications of
personnel, procedures, and equipment. Inspection and test records shall, as a
minimum, identify the inspector or data recorder, the type of observation, the results, the
acceptability, and the action taken in connection with any deficiencies noted. Records
shall be identifiable and retrievable. Consistent with applicable regulatory requirements,
the applicant shall establish requirements concerning record retention, such as duration,
location, and assigned responsibility.
Enforcement
Contrary to the above requirements, on November 23, 2009, during resolution of
AR 00988866, RR B Motor Change out Spreader Beam NDE INSP Report Missing,
the licensee approved a decision to recreate from recollection of memory the missing
NDE report and, therefore, failed to maintain a sufficient quality record providing
evidence of the NDE. Failure to maintain a sufficient record that provides evidence of
the NDE affecting quality of the safety-related spreader beam was a violation of
10 CFR 50, Appendix B, Criterion XVII. Because this violation was of very low safety
significance and was entered into the CAP, this violation is being treated as an NCV
consistent with Section VI.A.1 of the NRC Enforcement Policy.
(NCV 05000461/2011008-02 Failure to Maintain Quality Record as Evidence of
Activity Affecting Quality of Safety-Related Equipment). The licensee entered this
issue into the CAP as AR 1223723.
(1)
The effectiveness of corrective actions for the items reviewed by the inspectors was
generally appropriate for the identified issues. Over the two year period encompassed
by the inspection, the inspectors identified no significant examples where problems
recurred. The inspectors did identify one weakness associated with the stations use of
EFRs to evaluate Corrective Actions to Prevent Recurrence (CAPR). While reviewing
Root Cause Evaluations performed since the last biennial PI&R inspection in 2009, the
inspectors identified six examples where Clinton Power Station failed to perform EFRs
as required by the station's CAP procedures.
Effectiveness of Corrective Actions
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
August 17, 2011
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
ERRATA TO CLINTON POWER STATION, UNIT 1, NRC PROBLEM
IDENTIFICATION AND RESOLUTION INSPECTION REPORT
Dear Mr. Pacilio:
On July 8, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Problem Identification
and Resolution Inspection Report 05000461/2011008 (ML11189A129). In the Inspection
Report, the alphanumeric identifier for the cross-cutting aspect for non-cited violation (NCV)05000461/2011008-02 was incorrect. Please replace pages 2 and 11 of Inspection Report 05000461/2011008 with the enclosed corrected pages.
We apologize for any inconvenience to you and your staff.
Sincerely,
/RA/
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Docket Nos. 50-461
License Nos. NPF-62
Enclosure:
Errata for Inspection Report 05000461/2011008
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Distribution via ListServ
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DATE
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08/17/11
OFFICIAL RECORD COPY
Letter to M. Pacilio from M. Ring dated August 17, 2011
SUBJECT:
ERRATA TO CLINTON POWER STATION, UNIT 1, NRC PROBLEM
IDENTIFICATION AND RESOLUTION INSPECTION REPORT
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