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 Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items Priority Results In October of 2009, Bodycote and Hydroaire began Double Tempering Process for 416 SS couplings that If rework Examine Bodycote are currently 1a) Improper coupling occurred A. Verz velt NDT results for Low installed in P-7C, and P-7B Heat Coupling hardness caused by during the manufacutring couplings treatment details Design or deviation of heat process the are not wholly Manufacture treating from specified expected life consistent procedure 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 procedure rc%.r-rceport CR-PLP-2011-03902 Page 51 of 136
Attachment II - Failure Mode Analysis Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items Priority Results Coupling #7 had varying hardness across the part, where one end 1 b) Improper coupling was out of spec, while the other Coupling hardness caused by temperature gradient Look for inconsistent was in spec.
Design or Manufacture within furnace during Yim (LPI) hardness,, tensile, 0
- 3 installed in 2011 manufacturing and charpy results had min max delta process of 5.7.
LPI report does not address the typical expected hardness ranges across the part.
Coupling 1c) Improper Design or hardness caused by inadequate cooling 0
See 1 High see Row 3 Manufacture process low impact Independent testing low impact toughness of fracture toughness values Coupling Design or 1d) Inadequate values toughness charpy v (indicated by the Manufactur hardness specification (indicated by Yim (LPI) notch, tensile testing High CVN) are seen 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 Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items Priority Results 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 Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items Priority Results Based on tempering curves for the batch of couplings installed in P-7A, P-7B and P-7C (Figure 4-2), the tempering le) Crack propagation temperatures are in the Microspecimen Coupling due to sulfide range to be examination of failed Design or inclusion and avoided Yim (LPI) 2011 coupling, Low SEM verifies Manufacture secondary heat between couplings, IGSCC of material treament 400°C and re-review re-re of 2009 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 Aspect lines cannot be completed within Refute Su pport Assigned to Action Items Priority Results RCE team SCC.
Neolube is Coupling 1f) Stress corrosion Neolube is comprised of in alcohol graphite Perform chemical comprised of Design or cracking initiated b neolubeg by suspension, neither of Yim (LPI) uof failed High graphite in alcohol suspension Manufacture contamination which can cause SCC surfaces looking for effects of neolube neither of which 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items PriorityY Results RCE team Industry OE of IGSCC of 416 Based on Material SS, Perry analysis performed Root Cause by LPI test from 2004, procedure.
- 2) Improper coupling Commonly Used for Perry changed Compositional is quench hard n
d d
Design or material Pump Shafts and to 17-4PH SS.
Yim (LPI) analysis, chemical Low e e an Manufacture Couplings Are there analysis, and EDX.,
tempered 416 SS.
better material provide Recommendation options recommendation as is for Nitronic 60.
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 Stress
- 3) Overtorque from indicating foreign condition, may to impellers exists indicating foreqin 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" type KUL Keport CR-PLP-2011-03902 Page 56 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team Visual Inspection of Yim (LPI) and TIR on three Medium PENDING LPI 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 shaft in the Service Water on shaft Review Vibration indication of shaft Pumps, and may not journals Shafts Program Engineering Data, and effects of Low imbalance, be abnormal
- 4,#5,#6.
Seimic Supports sensativity of data to shaft imbalance is poor based on location of data samp le P-7C has been System Engineering, review WI for Low repacked 3 times DeBusscher packing adjustment since 2009 failure.
No issues noted 4a) Improper packing adjustment/ installation Bronze bearing under Wear patterns Realign shafts and Stress result in poor shaft packing box maintains shaft alignment observed on shafts #4 # 5 Yim (LPI) document wear LCO PENDING LPI aligment causing through packing box
- 6 patterns REPORT failure of couplin g RI.C RepurE C R-PLP-2011-03902 Page 57 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team Verify pump movement while out PENDING LPI Electircal Maintenance of service, when Medium Lower seismic restraints are REPORT 4b) Improper restraint is loosened Stress alignment caused by mounted near o-relative upper or lower failed coupling movement seismic restraint.
location Interview divers and observed during Maintenance maintenance High installation, no movement of unit required to install seismic restraints Initial reports from LPI Environmental
Electron Microscopy N/A IGSCC GS Iof material present and (SEM) analysis likel y cause Same chemical has been used for 10 years, if problematic No actions due input Environmental 5a) Changes in Water would not be isolated Clamtrol does from chemistry Effects Chemistry to P-7C. Annual possess N/A indicating that this is High N/A usage present for no chlorides not felt to be a 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team Sodium Hypochlorite Characterize Chlorination possesses chlorine increases Environmental 5b) Changes in Water chlorine.
concentration chlorides by Effects Chemistry Present at Chemistry experienced by High approximately 0.3 Service Water service water ppm, during the 40 Pumps 40 pumps, prior and minute period minutes/ day.
post 1 R21 daily Characterize chloride concentrations in Lake Water Chemistry Lake Michigan High 9.72 ppm chlorine Environmental 5b Changes in Water possesses water, annually, seasonally and over noted Effects Chemistry Chlorides, and last few years is present at all times Tem perature, PH, Send sample to LPI Chemistry of service water, High with Temp, PH, and TDO of samp 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team sulfides),
consistent with stress corrosion cracking.
Hydroaire states that they have a gage and check these Evalaute coupling Coupling
- 6) Incorrect dimensions, P-7C,B,A Hydroaire and shaft thread Design or clearances in coupling all have same coupling Go/NoGo Hydroaire clearances and 0
PENDING LPI Manufacture to shaft (threading design.
Typical gage failed verfiy that threads REPORT same?)
experience with NoGo check are in tolerance, for couplings indicates no parts in question threading issues during installation 6a) 0 Low Coupling 6b) Threads not Evaluate existing Design or concentric with Yim (LPI) condition of threads High PENDING LPI 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, High PENDING LPI 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team
- 7) Shaft faces not Evidence of Derterimne cause of Galling on Shaft Stress square (perfectly flat) 1-4 shafts from failed galling Yim (LPI) galling of shaft end, LCO end determined to occur after failure and butted pump are square between and squareness of of coupling post shafts 5 and 6 shaft ends 5 and 6 failure damage Packing alignment Repack pump, and Stress
- 8) Pump alignment issues may not be l
t t th None Mechanical Maintenance check position of LCO re evan o
e stuffing box relative presence of packing to shaft box bearing Sweep stuffing box As found shaft to Mechanical Maintenance bore, TIR etc....
Medium stuffing box, 3 -4 p laces, 0.002" WR - 246107, FIN compare levelness 0
PENDING LPI of head mounting REPORT flan g e to sole plate 0
Check fit, for the LCO followin g 1.
Radial Chamfered fit Mechanical Maintenance clearance fit LCO such that no between column and clearance exists head durin g installation.
2.
Concentricity Mechanical Maintenance of stuffing box Medium bearing to upper head reg ister F%%,r-rcepori CR-PLP-2011-03902 Page 61 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team When was the head Head not Engineering last machined (prior Medium machined during 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 Stress 8b) Nonconcentric Disassemble pump, and spiders/ After disassembly in the Spider Mechanical Maintenance looking for non-LCO shop measure concntric spiders 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results 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 Stress upper column to pump head and Mechanical Maintenance check position of stuffing box relative LCO See reference 40 stuffin g box to shaft 0
0 Bronze bearing mounted directly below Evidence of A change in the
- 11) Shaft Wobble packing box should restrain shaft whip uneven wear on shaft Evaluate packing for type of packing used in P-7C Stress allowed by shaft wear at the packing Initial failure modes journals Shafts System Engineering continued use in Low pump, would nott analysis gives
- 4 and #5 and Service Water Pump affect the failure failure 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 RCE Report CR-PLP-2011-03902 Service Water Pump would not Page 63 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team change the failure mode of the coupling event Install Prox Probes Program to measure and Medium PENDING LPI Engineering/Maintenance 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, Stress
- 12) Reverse rotation observing no rotation.
direction noted System Engineering reverse rotation Hlgh potential exists for 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" Cycle and startin g during RCE Report CR-PLP-2011-03902 Page 64 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results 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 System Engineering reverse High check valve leak 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 Perform ultrasonic due to part design.
Coupling coupling from factory (stress risers - vent Cracks do not appear the venthole vertical testing and Inspection of Design or M
f t
hole thru threads, to go through the vent location, and Yim (LPI) destructive testing of High coupling failure modes and FEA anu ac ure machining of threads, g
hole.
appear to parts looking for 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team venthole
, but not through vent hole Coupling 13a) Defects caused by machining Cracks do not appear Examine interior of Design or including the vent to go through the vent Yim (LPI) drilled hole, looking Medium PENDING LPI REPORT Manufacture hole.
hole.
for sources of FME 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 Stress startup (coupler dimension and only by coating of N/A lack of wear noted indicates failure stressor, load applied 0.002", and still in nitrile on shaft on rubber sleeve 0
mode not of to shaft by dry spec.
In addtion, 4 journal bearings "single overload" bearing) tenisile testing type indicates that this failure was not a single overload type KU r Kepor[
CR-PLP-2011-03902 Page 66 of 136
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team Operating at Design Speed, longevity of of other pumps indicates No Actions, due to Stress
- 15) Operation at not running at critical Vibration data Vibration data critical speed speed, Vibration N/A indicating not 0
does not support testing indicates NO operating at critical this conclusion large 1X frequency speed response
- 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 -
High modes and FEA 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
Attachment II - Failure Mode Analysis Failure Mode (yellow Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team MT testing of Coupling #7 and Yim (LPI)
Destructive - look for High
- 17) Dead head start Typical pump response during Lab data indicates following rebuild and deadheaded start is to Stress evaluation of failure is not of Stress quarterly surveillance test caused coupling
,jump". Shaft coupling Yim (LPI) coupling with consideration to Medium "single overload event" type does damage or bending of failures have not occurred immediately shock load not support this shaft after a start failure cause A before and after Documentation Stress
Document wear patterns on journals does not support does es improper not support refutes this t as a cause rct,r rceporr CR-PLP-2011-03902 Page 68 of 136
Attachment II - Failure Mode Analysis Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items Priority Results Does not relate to coupling failure, unless Mech Mainteance is stretching the column In work CR-PLP-2011-significantly during lift setting however total instruction Determine basis for 03967 & RFI 18 t
- 19) Improper pump lift float is verified and there is a choice of two the 1/2" and 3/8 pump lift settings in associated with P-7C 8/2011 ress setpoint matches design, in different System Engineering Work Instruction Medium Coupling Failure addtion, adjustment of float is done by hand y
settings, this Possible Source Jim Work methods making it very unlikely differs from Alderink do not support this as a cause for the that significant drawings?
observed failure addtional stresses are created during this process P-7A/C has had large History shows no
- 20) Increase load by organic blockage System Engineering Review ESOMS and association Stress back ressure from p
occur with no recent Debuscher characterize strainer Low between Strainer strainer blockage 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 Aspect lines cannot be completed within Refute Support Assigned to Action Items Priority Results RCE team Over 18 months, the sand collection within the service water bay ranges from 0-4",
Review vibration Sand collection in
- 21) F 21)
Flow l
where the low point is history over time service water bay charactoristic near the service water Document history of is minimal, Stress changes due to sand pumps. Sand collection rate is linear System Engineering sand review from service water bay Low typically 0" depth in flow field of build up in intake 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 Stress
- 22) Pump assembly Similar procedure for P-7A, and P-76 which HydroAire dimensional changes due to High changes have not yet failed.
2009 rebuilt of
- pump, Review EC for 2009 rebuild P-7C
- 23) Component P-7B, and P-7A have couplings were changed Review design and Stress replacements within stainless steel couplings and no to stainless HydroAire dimensional changes due to High rfi-12 last 5 years failures as of et yet steel during
- rebuild, 2009 rebuilt of pump rior to that RI.C 1.
JUIL CR-PLP-2011-03902 Page 70 of 136
Attachmen t II - Failure Mode Analysis Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items PriorityY Results 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 Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Su pport Assigned to Action Items Priority Results Coupling
- 25) Coupling design -
Recommend and rock-candy Design or Entire coupling D
prepare Design appearance, threaded vs relief esign Engineering Change package for High characteristic of Manufacture in center Coupling Design 9n intergranular Chan ges stress corrosion SEM examination revealed the fracture surface morphology to exhibit a
- Perry, rock-candy Palsades appearance, failure all Perform chemical characteristic of Environmental
- 26) Corrosion caused above non-analysis of failed intergranular Effects by environmental g
Yim (LPI) surfaces looking for High stress corrosion conditions water le vels le environmental cracking (IGSCC) within the within 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 Aspect Failure Mode (yellow lines cannot be completed within RCE team Refute Support Assigned to Action Items Priority Results Fleet Call with other plants that P-7A-Wl-SWS-M-03, Some Fleet have raw water Palisades
- 27) Maintenance -
P-7B/C Wi-SWS-M -04 installation vertical turbine practices found Stress Pump Assembly p
y
Coupling practices differ Maintenance pumps with High meeting or Practices Assembly/Disassembly from Palisades treaded couplings.
exceeding fleet the same Practices Send out work standards instruction for maintenance of pum p, p rior to P-7A and P-7C have similar
- 28) P-7C has P-7C has Compare run time, operating cycle, P-Environmental E
different operation Similar metals, chemical environment, failed 2 couplings P System Engineering, idle time, average operating interval Hi h
7B has had different cycle due ffects cycle from P-7B1 P 7A results pump design 7B and P-7A Aaron Verzywvelt periods for Service g
to saving the have not Water Pumps pump during early 2010 due to degraded performance 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 ges to affected personnel.
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