IR 05000456/2014010
| ML14329A035 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/24/2014 |
| From: | Eric Duncan Region 3 Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| EA-13-209 IR 2014010 | |
| Download: ML14329A035 (13) | |
Text
November 24, 2014
SUBJECT:
BRAIDWOOD STATION-NRC FOLLOW UP INSPECTION REPORT 05000456/2014010 AND 05000457/2014010
Dear Mr. Pacilio:
On October 15, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a follow up inspection for six Severity Level (SL) IV violations identified between January 1, 2013, and December 31, 2013, at your Braidwood Station. The enclosed report documents the results of this inspection, which were discussed on October 15, 2014, with Mr. M. Kanavos and other members of your staff.
The objectives of this follow up inspection were to provide assurance that: (1) the cause(s)
of multiple SL IV traditional enforcement violations were understood by the licensee; (2) the extent of condition and extent of cause of multiple SL IV traditional enforcement violations were identified; and (3) licensee corrective actions to traditional enforcement violations were sufficient to address the cause(s).
The inspection consisted of an examination of activities conducted under your license as they relate to safety, compliance with the Commissions rules and regulations, the conditions of your operating license, and the objectives stated above.
Based on the results of this inspection, the inspector determined that, in general, the causes of the violations were adequately understood, the extent of condition and extent of cause of the violations were identified to the extent required by station procedures, and corrective actions planned or taken were sufficient to address the causes.
Based on the results of this inspection, no findings were identified. In accordance with 10 CFR 2.390 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 NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA Ray Ng Acting for/
Eric R. Duncan, Chief Branch 3 Division of Reactor Projects
Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77
Enclosure:
IR 05000456/2014010; 05000457/2014010 w/Attachment: Supplemental Information
REGION III==
Docket Nos:
50-456; 50-457 License Nos:
05000456/2014010; 05000457/2014010 Licensee:
Exelon Generation Company, LLC Facility:
Braidwood Station Location:
Braceville, IL Dates:
October 7 through October 15, 2014 Inspector:
Brent Boston, Reactor Engineer, Branch 3
Approved by:
E. Duncan, Chief Branch 3 Division of Reactor Projects
SUMMARY OF FINDINGS
Inspection Report 05000456/2014010, 05000457/2014010; 10/7/2014-10/9/2014; Braidwood
Station, Units 1 and 2; Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period.
This report covers a 3-day period of inspection by a Branch 3 Reactor Engineer. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.
The inspector concluded that, in general, for these violations, the causes were understood by the licensee, the extent of condition and extent of cause were identified to the extent required by Braidwood Station procedures, and the licensees corrective actions were sufficient to address the identified causes.
REPORT DETAILS
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety and Security
4OA5 Other Activities
.1 Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement
Violations in the Same Area in a 12-Month Period (Inspection Procedure 92723)
This inspection was conducted in accordance with Inspection Procedure (IP) 92723, Follow Up Inspection for Three or More Severity Level (SL) IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, to assess the licensees evaluation of six SL IV violations that occurred within the area of impeding the regulatory process from January 1, 2013, to December 31, 2013. These violations were documented in NRC Inspection Reports as:
- (1) Non-Cited Violation (NCV)05000456/2013002-01; 05000457/2010002-01;
- (2) Licensee Event Report (LER) 2012-003-01;
- (3) NCV 05000456/2013004-01; 05000457/20105004-01;
- (5) NCV 05000456/2013005-03; 05000457/2013005-03; and
- (6) Violation (VIO)05000457/2013008-01 (EA-13-209).
The inspection objectives were to:
- Provide assurance that the causes of multiple SL IV traditional enforcement violations were understood by the licensee;
- Provide assurance that the extent of condition and extent of cause of multiple SL IV traditional enforcement violations were identified; and
- Provide assurance that licensee corrective actions (CAs) to traditional enforcement violations were sufficient to address the causes.
The inspector reviewed the cause evaluation associated with each of the issues and the Common Cause Analysis (CCA) 1609235, Six Traditional Enforcement NRC Violations in the Last 12 Months. Additionally, the inspector reviewed Licensee Check-In Self-Assessment Report 1630578, Pre-NRC Inspection Check-in: Follow-up Inspection for Three or More SL IV Traditional Enforcement Violations in the Same Area in a 12-Month Period. The inspector reviewed CAs to address the identified causes.
The inspector also held discussions with licensee personnel to ensure that the causes were understood and CAs were appropriate to address the causes.
.2 Evaluation of the Inspection Requirements
2.01 Review of Problem Identification a.
Determine that the licensees evaluation identifies how each of the issues were identified, how long each issue existed, and prior opportunities for identification The inspector determined that the licensees evaluation addressed how each of the issues were identified, how long they existed, and prior opportunities for identification.
Each issue was individually evaluated through the licensees Corrective Action Program (CAP). Additionally, the licensee performed a collective evaluation for the six SL IV violations in 2013 through a pre-NRC inspection self-assessment.
b. Findings
No findings were identified.
2.02 Evaluate Cause, Extent of Condition, and Extent of Cause Evaluations a.
Determine that the group of Severity Level IV violations received an evaluation at an appropriate level of detail using a systematic method(s) to identify cause(s)
The inspector determined that the SL IV violations were reviewed collectively using a systematic process to identify any common cause(s). The inspector determined this review contained an appropriate level of detail. The inspector verified that each SL IV violation was adequately evaluated in accordance with Braidwood Stations CAP requirements. The licensees CCA identified two major common elements and used them to group most of the violations into two groups for additional consideration. These groups were Failure to Make a Required Report to the NRC and Legacy Violations.
The term legacy violations was used to describe NRC violations where the performance deficiency occurred greater than 5 years ago. The licensee also assessed the cause(s) for individual violations.
b.
Determine that the evaluation included a consideration of how prior occurrences in the same traditional enforcement area (willfulness, regulatory process, or consequences)were addressed by the licensee The licensee chose to include an additional SL IV violation from 2012 (NCV 05000456/2012004-05; 05000457/2012004-05) involving a failure to submit a required report which broadened the scope of their CCA. The inspector determined that the licensees evaluation included a consideration of how prior occurrences in the area of impeding the regulatory process were addressed. The licensees self-assessment of their CCA deliberately reviewed four SL IV traditional enforcement violations within the area of impeding the regulatory process which had occurred at Braidwood during the year ending September 30, 2011, checking for repeat or similar problems and found no commonality with the recent issues. The CCA also considered operational experience regarding failure to make required reports to the NRC from other sites.
The inspector reviewed the SL IV violations to determine if they were due to a more fundamental concern involving weaknesses in the stations CAP. The inspector did not identify any commonality among the SL IV violations that suggested a fundamental weakness with the stations CAP.
c.
Determine that the evaluation addresses the extent of the condition and the extent of cause of the problem The inspector reviewed the individual CAP items for each of the SL IV violations as well as the self-assessment. The inspector determined that the licensee CAP process augmented by the CCA addressed the extent of condition and the extent of cause in accordance with the procedural requirements.
d. Findings
No findings were identified.
2.03 Evaluate Corrective Actions a.
Determine that appropriate corrective action(s) are specified for each cause identified for the group of violations or that there is an evaluation indicating that no actions are necessary The inspector determined that appropriate CAs were specified for the causes identified for each of the SL IV violations.
The licensees CCA identified Failure to Make a Required Report to the NRC as a common element in three of the SL IV violations considered in the CCA and addressed this by extensive review of the Exelon Reportability Reference Manual and training for selected managers on application of the reportability manual. The inspector reviewed the training material and the current Reportability Reference Manual and identified no deficiencies.
Three violations shared the common element of being Legacy Violations; two of these three involved 10 CFR 50.59 issues. The licensees CCA identified several process improvements which appear likely to reduce future 50.59 deficiencies. The licensee also performed extensive review of a sampling of 50.59 screenings and 50.59 evaluations looking for additional issues but found none. Appropriateness of the licensees corrective action for the 50.59 issues was further demonstrated by NRC Inspection Report 05000456/2014008; 05000457/2014008, "Braidwood Station, Units 1 and 2 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications Baseline Inspection Report," dated March 27, 2014, which included seven samples of 50.59 evaluations and 13 samples of 50.59 screenings, as defined in IP 71111.17, with no findings identified.
b.
Determine that the corrective actions have been prioritized with consideration of the regulatory compliance The inspector determined that CAs were adequately prioritized with consideration of regulatory compliance.
Procedure PI-AA-125, Corrective Action Program Procedure, provided guidance for prioritizing CAs. A sample review conducted by the inspector indicated that CAs were appropriately prioritized.
c.
Determine that a schedule has been established for implementing and completing the corrective actions The inspector determined that a schedule was established for implementing and completing the CAs.
Procedure PI-AA-125 provided guidance for establishing due dates for CAs. The inspector conducted a sample review of completed and planned CAs and did not identify any discrepancies.
d.
Determine that measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence Measures of success were developed for determining the effectiveness of the CAs to prevent recurrence. The licensee's CCA defined a specific measure of success for the corrective actions addressing the violations related to making required reports to the NRC as part of evaluating the effectiveness of corrective actions. This measure focuses on making all required reports throughout calendar year 2014.
e. Findings and Observations
No findings were identified.
4OA6 Management Meeting
.1
Exit Meeting Summary
On October 15, 2014, the inspector presented the inspection results to Mr. M. Kanavos, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Kanavos, Site Vice President
- M. Marchionda, Plant Manager
- J. Bashor, Engineering Manager
- V. Cwietniewicz, Corporate Emergency
Preparedness Manager
- A. Ferko, Operations Manager
- M. Jesse, Corporate Regulatory Assurance Manager
- S. Reynolds, Nuclear Oversight Manager
- P. Raush, Regulatory Assurance Manager
- D. Stiles, Site Training Director
- M. Abbas, NRC Coordinator
Nuclear Regulatory Commission
- E. Duncan, Chief, Reactor Projects Branch 3
- J. Benjamin, Senior Resident Inspector, Braidwood
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
None
Discussed
- 05000456/2012-003-01;
- 05000457/2012-003-01 LER Fuel Handling Incident Area Radiation Monitors Inoperable Due to Incorrect Alarm Setpoints
- 05000457/2013002-01 NCV Failure to Perform an Adequate 10 CFR 50.59 Evaluation Removing the Positive Displacement Pump from the Current Licensing Basis
NCV Failure to Perform a Required 10 CFR 50.59 Evaluation
NCV Failure to Maintain Accurate Operator Logs
NCV Failure to Submit Report Required by CFR 50.72(b)(3)(xiii)
VIO Inaccurate/Incomplete Information For Exemption Request From 10 CFR 50.60.