ML120100496
| ML120100496 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/05/2012 |
| From: | Entergy Nuclear Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML1200100495 | List: |
| References | |
| EA-11-241, EA-11-243, PNP 2012-06 CR-PLP-2011-03902 | |
| Download: ML120100496 (25) | |
Text
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priorit y Results completed within RCE team In October of 2009, Bodycote and Hydroaire began Double Tempering Process for 416 SS couplings that If rework Examine Bodycote are currently occurred A. Verz velt NDT results for installed in P-7C, 1a) Improper coupling Low during the couplings and P-7B . Heat Coupling hardness caused by treatment details Design or deviation of heat manufacutring process , the are not wholly Manufacture treating from specified consistent procedure expected life could have between certified beenn reduced. batches, however hardness testing indicated all parts were sat.
Review Hydroaire/Bodycote LPI procedures for Medium rfi-62 deviations from p rocedure rc%.r- rceport CR-PLP-2011-03902 Page 51 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority completed within Results RCE team Coupling #7 had varying hardness across the part, where one end was out of spec, 1 b) Improper coupling while the other hardness caused by was in spec.
Coupling Look for inconsistent temperature gradient #3 Design or Yim (LPI) hardness,, tensile, 0 within furnace during installed in 2011 Manufacture and charpy results manufacturing had min max delta process of 5.7. LPI report does not address the typical expected hardness ranges across the part.
1c) Improper Coupling hardness caused by Design or 0 See 1 High see Row 3 inadequate cooling Manufacture p rocess low impact Independent testing low impact toughness of fracture toughness values Coupling values toughness charpy v (indicated by the 1d) Inadequate Design or (indicated by Yim (LPI) notch, tensile testing High CVN) are seen hardness specification Manufactur e the CVN) are on 2009, 2011 failed in the couplings seen components, and that have failed in the other cou p lin g s with most CVN RCE Report CR-PLP-2011-03902 Page 52 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team couplings that values in the have failed single digits at with most CVN the temperature values in the range of the single digits at service water the (refer to Table 3-temperature 7).
range of the service water (refer to Table 3-7 ) .
RCE Report CR-PLP- 2011-03902 Page 53 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Based on tempering curves for the batch of couplings installed in P-7A, P-7B and P-7C (Figure 4-2), the tempering temperatures le) Crack propagation are in the Microspecimen Coupling due to sulfide range to be examination of failed Design or inclusion and 2011 coupling, SEM verifies avoided Yim (LPI) Low Manufacture secondary heat between couplings, IGSCC of material re-review re-re of 2009 treament 400°C and 580°C (752°F metalurgical report to 1076°F) for 416SS. These tempering temperatures can lead to low toughness and susceptibility of the material to
-li RePUI L CR-PLP-2011-03902 Page 54 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Su pport Assigned to Action Items Priority completed within Results RCE team SCC.
Neolube is 1f) Stress corrosion Neolube is comprised comprised of Coupling of graphite in alcohol Perform chemical cracking initiated by b uof failed graphite in alcohol Design or g suspension, neither of Yim (LPI) High neolube surfaces looking for suspension ,
Manufacture which can cause SCC neither of which contamination effects of neolube in 416 SS can cause SCC in 416 SS
-ll RCpUII CR-PLP-2011-03902 Page 55 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priorit y Results completed within Y RCE team Industry OE of IGSCC of 416 Based on Material SS, Perry analysis performed Root Cause by LPI test from 2004, Coupling material procedure.
Coupling Commonly Used for Perry changed Compositional is quench
- 2) Improper coupling hard e n e d an d Design or Pump Shafts and to 17-4PH SS. Yim (LPI) analysis, chemical Low material tempered 416 SS.
Manufacture Couplings Are there analysis, and EDX.,
better material Recommendation provide options is for Nitronic 60.
recommendation as available? to material for IPEC when to coupling Nitronics 50 Boroscope Interviews with inspection of P-9C Material that Maintenance to Bowl Assembly could have Geerlings verify that no Medium Results: Nothing Nothing was observed caused OT evidence of damage was observed
- 3) Overtorque from indicating foreign condition, may to impellers exists indicating foreqin Stress foreign material material causing have fallen or material.
overtorque otherwise Tensile testing missed during Evaluated failed indicates failure inspection Yim (LPI) coupling for single Low mode not of overload condition "single overload" ty pe KUL Keport CR-PLP-2011-03902 Page 56 of 136
Attachment II - Failure Mode Analysis Failure Mode ( yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Visual Inspection of Yim (LPI) and TIR on three PENDING LPI Medium shafts removed REPORT Available vibration Uneven wear is Evidence of data at the motor
- 4) Misalignment of typically experienced uneven wear does not provide Stress in the Service Water on shaft indication of shaft shaft Review Vibration Pumps, and may not journals Shafts Program Engineering imbalance, Data, and effects of Low be abnormal #4,#5,#6. sensativity of data Seimic Supports to shaft imbalance is poor based on location of data sam p le P-7C has been System Engineering, review WI for repacked 3 times DeBusscher packing adjustment Low since 2009 failure.
No issues noted 4a) Improper packing Bronze bearing under Wear patterns adjustment/ installation Realign shafts and Stress result in poor shaft packing box maintains observed on PENDING LPI shaft alignment Yim (LPI) document wear LCO aligment causing shafts #4 , # 5 , REPORT through packing box #6 patterns failure of couplin g RI.C RepurE C R-PLP-2011-03902 Page 57 of 136
Attachment II - Failure Mode Analysis Failure Mode ( yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Verify pump movement while out Electircal Maintenance PENDING LPI of service, when Medium restraints are REPORT 4b) Improper Lower seismic restraint is loosened alignment caused by o- relative Stress mounted near upper or lower movement seismic restraint. failed coupling location observed during Interview divers and Maintenance High installation, no maintenance movement of unit required to install seismic restraints Initial reports from LPI Environmental 5) Stress Corrosion indicate that Perform Scanning Yim (LPI) Electron Microscopy GS verifies SEM Effects Cracking SCC is N/A (SEM) analysis Iof IGSCC material present and likel y cause Same chemical has been used for 10 years, if problematic No actions due input Environmental 5a) Changes in Water Clamtrol does from chemistry would not be isolated Effects Chemistry possess N/A indicating that this is High N/A to P-7C. Annual chlorides not felt to be a usage present for no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> contributor p er ear RCE Report CR-PLP-2011-03902 Page 58 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Sodium Hypochlorite Characterize Chlorination possesses chlorine increases Environmental 5b) Changes in Water chlorine. concentration chlorides by Effects Chemistry Chemistry experienced by High approximately 0.3 Present at Service Water service water ppm, during the 40 Pumps 40 pumps, prior and minute period minutes/ da y . post 1 R21 daily Characterize chloride concentrations in Lake Water Chemistry Lake Michigan 9.72 ppm chlorine High water, annually, noted Environmental 5b Changes in Water possesses Chlorides, and seasonally , and over Effects Chemistry last few years .
is present at all times Tem p erature, PH, Send sample to LPI Chemistry of service water, High with Temp, PH, and TDO of sam p le EDS analysis of fracture surface Environmental Microbiological No discussion of MIC Perform Chemical revealed the Effects induced corrosion in lab report Yim (LPI) analysis of coupling Low presence of deposits corrosive agents (chlorides, oxides and RCE Report CR-PLP-2011-03902 Page 59 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team sulfides),
consistent with stress corrosion cracking.
Hydroaire states that they have a gage and check these Evalaute coupling
- 6) Incorrect dimensions, P-7C,B,A Hydroaire and shaft thread Coupling clearances in coupling all have same coupling Go/NoGo clearances and PENDING LPI Design or Hydroaire 0 to shaft (threading design. Typical gage failed verfiy that threads REPORT Manufacture same?) experience with NoGo check are in tolerance, for couplings indicates no parts in question threading issues durin g installation 6a) 0 Low Coupling 6b) Threads not Evaluate existing Design or concentric with Yim (LPI) condition of threads PENDING LPI High Manufacture cou p lin g within cou p lin g REPORT Provide photos of shaft ends near failed coupling, or 7a) RCE Team shafts if available, PENDING LPI High looking for evidence REPORT of Galling of 2009 failure RCE Report CR-PLP-2011-03902 Page 60 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Evidence of Derterimne cause of Galling on Shaft
- 7) Shaft faces not end determined to Stress 1-4 shafts from failed galling galling of shaft end, square (perfectly flat) Yim (LPI) LCO occur after failure pump are square between and squareness of and butted of coupling , post shafts 5 and 6 shaft ends 5 and 6 failure dama g e Packing alignment Repack pump, and Stress issues may not be check position of
- 8) Pump alignment None Mechanical Maintenance LCO re l evan t t o th e stuffing box relative presence of packing to shaft box bearing As found shaft to Mechanical Maintenance Sweep stuffing box Medium stuffing box, 3 -4 bore, TIR etc....
p laces, 0.002" WR - 246107, FIN compare levelness PENDING LPI of head mounting 0 REPORT flan g e to sole p late 0 Check fit, for the LCO followin g
- 1. Radial Chamfered fit clearance fit such that no Mechanical Maintenance LCO between column and clearance exists head durin g installation.
- 2. Concentricity Mechanical Maintenance of stuffing box Medium bearing to upper head re g ister F%%,r- rcepori CR-PLP- 2011-03902 Page 61 of 136
Attachment II - Failure Mode Analysis Failure Mode ( yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Head not When was the head Engineering last machined (prior machined during Medium to 2009 failure???) 2009 rebuild of P-7C
- 1. How many times has this pump been repacked, because eccentric 3 Times since Engineering shaft position Priority 2009 coupling relative to the Failure packing is indicative of head to column assembl y 0 0 0 0 0 0 During disassembly, number columns Disassemble pump, and spiders/ After Stress 8b) Nonconcentric disassembly in the Spider Mechanical Maintenance looking for non- LCO concntric spiders shop , measure radial fit between spider and associated column. P-7A had RCE Report CR-PLP -2011-03902 Page 62 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team slop ranging up to 0.004" unlikely to cause misalignment issue due to 0.004
- 0.009 tolerance between shaft journal and rubber sleeve bearin g 8c) Alignment of Repack pump, and upper column to check position of Stress Mechanical Maintenance LCO See reference 40 pump head and stuffing box relative stuffin g box to shaft 0 0 Bronze bearing mounted directly below Evidence of A change in the packing box should uneven wear type of packing
- 11) Shaft Wobble Evaluate packing for used in P-7C Stress allowed by shaft wear restrain shaft whip . on shaft Initial failure modes journals Shafts System Engineering continued use in Low pump, would nott at the packing Service Water Pump affect the failure analysis gives #4 and #5 and evidence against #6 mode of the fatigue failure, typically coupling expected to be caused by cyclic stresses from shaft alignment issues System Engineering Evaluate need for Low The addition of hardened sleeve Hardened Sleeve Service Water RCE Report CR-PLP- 2011-03902 Pump would not Page 63 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team change the failure mode of the coupling event Install Prox Probes Program to measure and PENDING LPI Engineering/Maintenance Medium record shaft REPORT movement/vibrations 0 0 0 0 0 0 Lack of Anti- QO-14 states to Rotation check for reverse Feature on pump rotation, Pump, 1 prior to start, Rotation initate DRN to add QO-14 documents Opposite similar statement check valve closed, by nominal Characterize to SOP-15,
- 12) Reverse rotation observing no rotation. direction noted reverse rotation potential exists for Stress System Engineering Hlgh during pump start P-7A has similar during test behavior of P-7C rapid pump start distrubution but no bump when shut off after stop will failures (deadheaded) cause excessive WI-SWS-M-04 stresses to shafts 6.14 "Motor and couplings due Bump and to reverse rotation Pump Lift driven by gravity, Reset" C ycle and startin g durin g RCE Report CR-PLP- 2011-03902 Page 64 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team data from the reverse 2009-2011 rotation shows 27 start/stop intervals of less than 1.44 minutes in duration 12a) Reverse rotation No walkdown evidence Characterize No evidence of Stress from check valve leak of rotation in recent reverse check valve leak System Engineering High by memory behavior of P-7C 7C by or persistant when shut off reverse rotation Cracks are UT testing unable located within to be performed
- 13) Defect(s) in 2-3 threads of due to part design.
coupling from factory the venthole Perform ultrasonic Coupling Cracks do not appear testing and Inspection of (stress risers - vent vertical coupling failure Design or to go through the vent Yim (LPI) destructive testing of High hole thru threads, location, and modes and FEA M anu f ac t ure hole. parts looking for machiningg of threads, appear to indicates highest edges, etc)) grow outward defects stresses are within from thre a band 1-2 thread roots threads of RCE Report CR-PLP-2011-03902 Page 65 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team venthole , but not through vent hole 13a) Defects caused Coupling Cracks do not appear Examine interior of by machining PENDING LPI Design or to go through the vent Yim (LPI) drilled hole, looking Medium including the vent REPORT Manufacture hole. for sources of FME hole.
13b) 0 0 13c) 0 0 Expected Wear of Rubber bearing in Spider, noted only one
- 14) Contact of shaft coupling deviating with dry rubber on from nominal Observed No Actions, due to Tensile testing startup (coupler dimension and only by coating of indicates failure Stress lack of wear noted stressor, load applied 0.002", and still in nitrile on shaft N/A 0 mode not of on rubber sleeve to shaft by dry spec. In addtion, 4 journal "single overload" bearings bearing) tenisile testing type indicates that this failure was not a single overload typ e KU r Kepor[
CR-PLP-2011-03902 Page 66 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Operating at Design Speed, longevity of of other pumps indicates No Actions, due to
- 15) Operation at not running at critical Vibration data Vibration data Stress N/A indicating not 0 does not support critical speed speed, Vibration testing indicates NO operating at critical this conclusion large 1X frequency speed res p onse
- 16) Restart of pump Timing for the event Reverse Compare reverse shortly after shutoff described would be Rotation rotation time after Stress (e.g RT-8C, P-7C Pump Running, Observed 1 Engineering pump shut off to Medium start 26 s after DG bkr Stopped, then Running rotation over a typical shortest closes = OK) applied over 26-32 seconds. couple a pump restart times extra load to pump Pump reverse rotation seconds, UT testing unable shaft. observed for 2-5 8/11/11 to be performed seconds due to part design.
Inspection of coupling failure Yim (LPI) Nondestructive - modes and FEA High Ultrasonic Test indicates highest stresses are within a band 1-2 threads of venthole , but not throu g h vent hole RCE Report CR-PLP-2011-03902 Page 67 of 136
Attac hment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team MT testing of Coupling #7 and Destructive - look for #5 indicates Yim (LPI) High micro cracks cracking present in Coupling 7 due to IGSCC Typical pump
- 17) Dead head start Lab data indicates response during following rebuild and Stress evaluation of failure is not of deadheaded start is to quarterly surveillance coupling with "single overload Stress ,jump". Shaft coupling Yim (LPI) Medium test caused coupling consideration to event" type , does failures have not damage or bending of shock load not support this occurred immediately shaft failure cause after a start A before and after Documentation
- 18) Improper shaft measurement in the Document wear does not support Stress Yim (LPI) es improper coupling engagement work order package patterns on journals refutes this t as a cause rct,r rceporr CR-PLP-2011-03902 Page 68 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Does not relate to coupling failure, unless Mech Mainteance is stretching the column CR-PLP-2011-In work significantly during lift 03967 & RFI 18 instruction Determine basis for setting , however , total associated with P-there is a the 1/2" and 3/8 float is verified and 7C 8/2011
- 19) Improper pump lift choice of two pump lift settings in t ress matches design, in System Engineering Medium Coupling Failure setpoint different Work Instruction ,
addtion, adjustment of - Work methods settings, this Possible Source Jim float is done by hand , do not support this y differs from Alderink making it very unlikely as a cause for the drawings?
that significant observed failure addtional stresses are created during this process P-7A/C has had large History shows no
- 20) Increase load by organic blockage Review ESOMS and association Stress back ressure from occur with no recent System Engineering ,
p blockage Debuscher characterize strainer Low between Strainer strainer coupling failure DP over time backpressure and associated cou p lin g failure RCE Report CR-PLP -2011-03902 Page 69 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Over 18 months, the sand collection within the service water bay ranges from 0-4", Review vibration Sand collection in where the low point is history over time service water bay
- 21) Flow F
near the service water Document history of is minimal,
- 21) l charactoristic Stress changes due to sand pumps. Sand sand review from typically 0" depth collection rate is linear System Engineering Low build up in intake service water bay . in flow field of structure overtime, with the Listen for voiding pumps, unlikely relative collection of using a stethoscope cause of coupling sand in the service on discharge pipe failure water bay significanly reduced compared to the intake structure Review design and Similar procedure for dimensional
- 22) Pump assembly changes due to Stress P-7A, and P-76 which HydroAire High changes 2009 rebuilt of have not yet failed.
pump, Review EC for 2009 rebuild P-7C P-7B, and P-7A have couplings
- 23) Component were changed Review design and Stress stainless steel dimensional replacements within to stainless HydroAire High rfi-12 couplings and no changes due to last 5 years steel during failures as of yet et 2009 rebuilt of pump rebuild, rior to that RI.C 1. JUIL CR-PLP-2011-03902 Page 70 of 136
Attachmen t II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items PriorityY Results completed within RCE team were Carbon Steel, no failures associated with couples observed SEM examination revealed the fracture surface morphology to exhibit a rock-candy appearance, characteristic of Coupling Evaluate Failed intergranular Design or 24) Fatigue failure Yim (LPI) Coupling for Fatigue Medium stress corrosion Manufacture Failure cracking (IGSCC) as shown in Figure 3-10. This is typical for a quench and tempered steel, such as a 400 series martensitic steel.
N..C icepon CR-PLP-2011-03902 Page 71 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Su pport Assigned to Action Items Priority Results completed within RCE team
- 25) Coupling design - Recommend and rock-candy Coupling prepare Design appearance, Entire coupling Design or D esign Engineering Change package for High characteristic of threaded vs . relief Manufacture Coupling Design9n intergranular in center Chan g es stress corrosion SEM examination revealed the fracture surface morphology to exhibit a Perry, rock-candy Palsades appearance, failure all Perform chemical characteristic of
- 26) Corrosion caused analysis of failed intergranular Environmental above non-by environmental Yim (LPI) surfaces looking for High stress corrosion Effects le g conditions environmental cracking (IGSCC) water le vels within within the causes as shown in pump Figure 3-10. This is typical for a quench and tempered steel, such as a 400 series martensitic steel.
rc. mepori CR-PLP- 2011-03902 Page 72 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow lines cannot be Aspect Refute Support Assigned to Action Items Priority Results completed within RCE team Fleet Call with other plants that P-7A- Wl-SWS-M-03, Some Fleet have raw water vertical turbine Palisades
- 27) Maintenance - P-7B/C Wi-SWS-M -04 installation practices found Stress Pumpp Assemblyy ----------- Coupling practices differ pumps with Maintenance High meeting or Practices Assembly/Disassembly from Palisades treaded couplings .
Send out work exceeding fleet the same Practices standards instruction for maintenance of p um p, p rior to P-7A and P-7C have similar P-7C has operating cycle, P-
- 28) P-7C has Compare run time, Similar metals, failed 2 idle time, average 7B has had Environmental different operation System Engineering, different cycle due E ffects chemical environment, couplings , P operating interval Hi g h cycle from P-7B1 P Aaron Verzywvelt to saving the 7A , results pump design 7B and P-7A periods for Service have not Water Pumps pump during early 2010 due to degraded p erformance RCE Report CR-PLP-2011-03902 Page 73 of 136
Attachment III - Safety Culture Evaluation TA TABLE 1 - SAFETY CULTURE COMPARISON SAFETY CULTURE COMPONENT DESCRIPTION CR-PLP-2011-03902
- 1. Decision - Making Licensee decisions demonstrate that nuclear safety is an overriding priority: RC, - No indication RC2 - No indication CC1 - No indication CC2 - No indication CC3 - No indication
- 2. Resources The licensee ensures that personnel, equipment, procedures, and other RC, - No indication resources are available and adequate to assure nuclear safety. RC2 - Yes CC1 - No indication CC2 - Yes, significant CC3 - No indication
- 3. Work Control The licensee plans and coordinates work activities, consistent with nuclear RC, - No indication safety: RC2 - No indication CC1 - No indication CC2 - No indication CC3 - No indication
- 4. Work Practices Personnel work practices support human performance. RC, - No indication RC2 - No indication CC1 - No indication CC2 - No indication CC3 - No indication
- 5. Corrective Action The licensee ensures that issues potentially impacting nuclear safety are RC, - No indication Program promptly identified, fully evaluated, and that actions are taken to address safety RC2 - No indication issues in a timely manner, commensurate with their significance. CC1 - No indication CC2 - No indication CC3 - Yes, not si g nificant
- 6. Operating The licensee uses operating experience (OE) information, including vendor RC, - No indication experience recommendations and internally generated lessons learned, to support plant RC2 - No indication safety. CC1 - No indication CC2 - No indication CC3 - Yes, si g nificant
- 7. Self- and The licensee conducts self- and independent assessments of their activities and RC, - No indication Independent practices, as appropriate, to assess performance and identify areas for RC2 - No indication Assessments improvement. CC1 - No indication Kit report CR-PLP-2011-03902 Page 74 of 136
Attach ment III - Safety Culture Evaluation SAFETY CULTURE COMPONENT DESCRIPTION CR-PLP -2011-03902 CC2 - No indication CC3 - No indication
- 8. Environment For An environment exists in which employees feel free to raise concerns both to RC, - No indication Raising Concerns their management and/or the NRC without fear of retaliation and employees are RC2 - No indication encouraged to raise such concerns. CC1 - No indication CC2 - No indication CC3 - No indication
- 9. Preventing , A policy for prohibiting harassment and retaliation for raising nuclear safety RC, - No indication Detecting , and concerns exists and is consistently enforced. RC2 - No indication Mitigating CC1 - No indication Perceptions of CC2 - No indication Retaliation CC3 - No indication
- 10. Accountability Management defines the line of authority and responsibility for nuclear safety. RC, - No indication RC2 - Yes CC1 - No indication CC2 - No indication CC3 - No indication
- 11. Continuous The licensee ensures that a learning environment exists. RC, - No indication learning RC2 - No indication environment CC1 - No indication CC2 - No indication CC3 - No indication
- 12. Organizational Management uses a systematic process for planning, coordinating, and RC, - No indication change evaluating the safety impacts of decisions related to major changes in RC2 - No indication management organizational structures and functions, leadership, policies, programs, CC1 - No indication procedures, and resources. Management effectively communicates such CC2 - No indication chan g es to affected p ersonnel. CC3 - No indication
- 13. Safety policies Safety policies and related training establish and reinforce that nuclear safety is RC, - No indication an overriding priority in that: RC2 - No indication CC1 - No indication CC2 - No indication CC3 - No indication RGE Report CR-PLP-2011-03902 Page 75 of 136