IR 05000456/2011013
| ML120170382 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/17/2012 |
| From: | Eric Duncan Region 3 Branch 3 |
| To: | Pacilio M Exelon Generation Co |
| References | |
| IR-11-013 | |
| Download: ML120170382 (16) | |
Text
January 17, 2012
SUBJECT:
BRAIDWOOD STATION - NRC FOLLOW UP INSPECTION REPORT 05000456/2011013 AND 05000457/2011013
Dear Mr. Pacilio:
On December 15, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a follow up inspection for four Severity Level (SL) IV violations identified between October 1, 20 10 , and September 30, 201 1, at your Braidwood Station. The enclosed report documents the results of this inspection, which were discussed on December 15, 2011, with Mr.
D. Enright , 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 Commission's 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 action s planned and/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/
Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket No.
50-456; 50-457 License No. NPF-72; NPF-77
Enclosure:
Inspection Report 05000456/20110 13; 05000457/20110 13; w/Attachment: Supplemental Information
REGION III==
Docket No:
50-456; 50-457 License No:
05000456/2011013; 05000457/2011013 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station Location: Braceville , IL Dates: December 12 through December 15, 2011 Inspector: John Robbins , Byron Resident Inspector Approved by:
E. Duncan, Chief Branch 3 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report 05000456/2011013, 05000457/2011013; 12/12/2011
- 12/15/2011; Braidwood Station, Units 1 & 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 4-day period of inspection by the Byron Resident Inspector.
No findings were identified.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
The inspectors 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 licensee's corrective actions were sufficient to address the identified causes.
A. No findings were identified.
NRC-Identified
and Self-Revealed Findings B. None.
Licensee-Identified Violations
REPORT DETAILS
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
4OA5
.1 Other Activities
a. 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 licensee's evaluation of four SL IV violations that occurred within the area of impeding the regulatory process from October 1, 20 10, to September 30, 2011. These violations were documented in NRC Inspection Reports as:
- (1) N on-Cit ed Violation (NCV) 05000456/2010005
-02, 05000457/2010005
-02;
- (2) NCV 05000457/2011002
-01;
- (3) Notice of Violation (N O V) 05000456/2010503
-01; 05000457/2010503
-01; and
- (4) NCV 05000456/2011004
-06; 05000457/2011004
-06. The inspection objectives were to:
Inspection Scope P rovide 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. Additionally, the inspector reviewe d Licensee Check-I n Self-Assessment Report 1267093, "Pre-NRC Follow Up Inspection for Three or More SL IV Traditional Enforcement Violations in the Same Area in a 12
-Month Period." The inspector reviewed CA s 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 2.01 Evaluation of the Inspection Requirements
a. Review of Problem Identification The inspector determined that the licensee's evaluation addressed how each of the issues were identified, how long they existed, and prior opportunities for identification.
Determine that the licensee's evaluation identifies how each of the issues were identified, how long each issue existed, and prior opportunities for identification
3 Enclosure Each issue was individually evaluated through the licensee's Corrective Action Program (CAP). Additionally, the licensee performed a collective evaluation for the four SL IV violations through a pre-NRC inspection self-assessment. This self-assessment identified one deficiency concerning the Event Reporting process not being initiated in a timely manner as a result of untimely past operability reviews. This issue was entered into the licensee's CAP as Issue Report (IR) 1292145, "LER [Licensee Event Report] Reporting Delayed Due to Numerous ATI [Action Tracking Item] Extensions
." b. No findings were identified.
Findings 2.02 a. Evaluate Cause, Extent of Condition
, and Extent of Cause Evaluations The inspectors determined that the SL IV violations were reviewed collectively using a systematic process to identify any common cause(s). The inspectors determined this review contained an appropriate level of detail. The inspector verified that each SL IV violation was adequately evaluated in accordance with Braidwood Station's CAP requirements.
The lic ensee did not identify a common cause for the violations. Therefore, the licensee evaluated each issue individually.
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 identified an issue with the licensee's self-assessment efforts to investigate the failure to submit a timely report to notify the NRC of Residual Heat Removal (RH R) system performance problems (NCV 05000456/2010005
-02; 05000457/2010005
-02, "Failure to Submit a n L E R Per 10 CFR 73(a)(2)(v)"). In this case, the self-assessment effort focus ed on the technical aspects of the issue , rather than the underlying causes of the failure to submit a timely report for the loss of safety function of the RHR system. The inspector discussed this issue with the licensee and
, as a result
, the licensee subsequently entered this issue into t he ir CAP as IR 1302866 , "NRC Identified No Formal Evaluation for Untimely LER Submittal for RHR
." However, when the failure to submit the LER that resulted in the SL IV violation was first identified by the inspectors in September 2010, the licensee entered the issue into their CAP as IR 1292145. During this inspection
, the inspector confirmed that the issue was appropriately reviewed and addressed. In particular , IR 1155372, "RHR System Issue Resulting in LER," identified that the due date for a task in IR 1073616, "Perform Past Operability Review for RH R in Mode 4 ," had been extended 11 times such that the deadline for submitting the LER was exceeded and that appropriate supervision was unaware of the deadline. The licensee also identified that the action item associated with the LER submittal was coded as an ATI and therefore did not receive as high a level of review as was warranted.
4 Enclosure As a result, a revision to the Station Operating Committee (SOC)process was implemented. Specifically, for issues associated with operability or reportability, the process was revised to assign CAs (vice ATIs) to individual owners to elevate the level of management review.
In addition, Braidwood Station Policy Memorandum BR-40, "Expectations for Extending Issue Report Cause Investigations and Corrective Action Due Dates," required that the first CA extension be reviewed by the department head and that subsequent changes be approved by the Management Review Committee (MRC) or the Plant Manager. At the end of th is inspection, the licensee planned to revise Policy Memorandum BR-40 to enhance these requirements to preclude missing an LER submittal deadline. b. The inspector determined that the licensee's evaluation included a consideration of how prior occurrences in the area of impeding the regulatory process were addressed. The four SL IV violations were reviewed to determine if they were due to a more fundamental concern involving weaknesses in the station's CAP. The inspector did not identify any commonality among the four SL IV violations that suggested a fundamenta l weakness with the station's CAP.
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 c. A review of the station's CAP procedures identified that LS
-AA-125, "Corrective Actio n Program (CAP) Procedure,"
did not require an extent of condition review for a Class D (Work Group) evaluation unless it was specifically requested by the Ownership Committee or MRC. Procedure LS
-AA-125 , "Corrective Action Program Procedure
," only required an extent of condition evaluation for Class A (Root Cause) and Class B (Apparent Cause) evaluations.
Determine that the evaluation addresses the extent of the condition and the extent of cause of the problem The inspectors reviewed the individual CAP items for each of the four SL IV violations as well as the self-assessment. A number of the SL IV violations reviewed were categorized at the Class D level and the inspector determined that the licensee addressed the extent of condition and the extent of cause in accordance with the procedural requirements.
d. No findings were identified.
Findings 2.03 a. Evaluate Corrective Actions The inspector determined that appropriate CA s were specified for the causes identified for each of the SL IV violations.
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 5 Enclosure Because no common cause was identified for the group of violations, no CA was taken to address the group of violations collectively
.
b. The inspector determined that CAs were adequately prioritized with the consideration of regulatory compliance.
Determine that the corrective actions have been prioritized with consideration of the regulatory compliance Procedure LS
-AA-125 provided guidance for prioritizing CAs. A sample review conducted by the inspector indicated that CAs were appropriately prioritized.
c. The inspector determined that a schedule was established for implementing and completing the CAs.
Determine that a schedule has been established for implementing and completing the corrective actions Procedure LS
-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. The inspector determined that there were no measures of success developed for determining the effectiveness of the CAs to prevent recurrence.
Determine that measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence Procedures LS
-AA-125 and LS
-AA-125-1004, "Effectiveness Review Manual," provide d guidance for assigning and conducting effectiveness reviews. Effectiveness reviews were only required to be performed for CAs to prevent recurrence (CAPR) or for an individual CA that the Corrective Action Program Coordinators (CAPCOs) or MRC deem ed necessary. None of the CAs were required to have an effectiveness review completed and no additional actions were deemed necessary
The licensee's self-assessment identified that there were no effectiveness reviews established for the CAs associated with the four SL IV violations. Although there were no procedural requirements to perform effectiveness reviews
, the licensee's self-assessment concluded that the likelihood of recurrence was reduced due to the CA s planned and/or taken. e. No findings were identified.
Findings and observations
4OA6
.1 Management Meetings
On December 15, 2011, the inspector presented the inspection results to M r. D. Enright , and other members of the licensee staff. The licensee acknowledged the issues
Exit Meeting Summary
6 Enclosure presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
Attachment
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC
T
- D. Enright, Site Vice President
Licensee
- M. Kanavas, Plant Manager
- T. Tierney, Operations Support Manager
- L. Dworakowski, Regulatory Assurance Licensing Engineer
- J. Gerrity, Emergency Preparedness Manager
- R. Radulovich, Nuclear Oversight Manager
- T. Kirman, Maintenance Support Manager
- F. Gogliotti, Sr. Engineering Manager
- M. Abbas, Regulatory Assurance NRC Coordinator
- E. Dunca n, Chief, Reactor Projects Branch
Nuclear Regulatory Commission
- J. Robbins, Resident Inspector, Byron
- J. Benjamin, Senior Resident Inspector, Braidwood
Attachment
LIST OF ITEMS OPENED, CLOSED AND DISCUSS
ED Opened None. Closed None. Discussed 05000456/2010005
-02; 05000457/2010005
-02 NCV Failure to Submit a n LER Per 10 CFR 73(a)(2)(v)
-01 NCV Failure to Provide Complete and Accurate Information in LER 05000457/2010
-04-00 05000456/2010503
-01; 05000457/2010503
-01 N O V Changes to EAL [Emergency Action Level] Basis Decreases the Effectiveness of the Plan Without Prior NRC Approval
-06; 05000457/2011004
-06 NCV Modification of the AF [Auxiliary Feedwater] System Without Prior NRC Approval
Attachment
LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overall inspectio
n effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- IR 0906754; Improvements Needed to EP 50.54(Q)
Evaluations and Process, April 13, 2009 - IR 1073616; RH
R System Issue Associated with Westinghouse NSAL 09
-08, May 26, 2010
- IR 1105448; Addendum to Root Cause Report, Rev. 7
- IR 1105448; Unplanned LCO Entry Due to Operator Error, August 24, 2011
- IR 1155372; RH
R System Issue Resulting in LER
- Tracking, December 22, 2010
- IR 1166336; Inaccurate Information Contained in LER 2010
-004, January 21, 2011
- IR 1173606; Braidwood URI on EAL HU6 Classified as Violation, February 10, 2011
- IR 1183518; Receipt of NRC Green
Finding - Improper Change to EAL, March 1, 2011
- IR 1184456; Braidwood HU6 EAL Violation Requires Written Response, March 7, 2011
- IR 1195224; Two NRC Enforcements Within a 12 Month Period, March 30, 2011
- IR 1199710; Three
NRC Severity Level IV Violations Within a 12 Month Period, April 6, 2
011 - IR 1244984; Apparent Cause Report for 50.54(q) NCV, September 16, 2011
- IR 1258017; 1A/2A AF Pump Discharge Crosstie Regulatory Concern, August 22, 2011
- IR 1263931; Three Traditional Enforcement Violations Need Detailed Answer, September 16, 2011 - IR 1267093; Self
-Assessment Report, November 17, 2011
- IR 1273856; Potential NRC Severity Level IV Violation, October 5, 2011
- IR 1292145; LER Reporting Delayed Due to Numerous ATI Extensions, November 19, 2010
- IR 1299906; NRC Identified Missed 10CFR50.73 Notification for HELB Design, March 8, 2011
- LER 2010-004-00; Unit 2 Unplanned Limiting
Condition for Operation Entry Due to Low Header Pressure on the 2B Essential Service Water Pump, October 25, 2011
- BR-40; Braidwood Station Policy Memorandum
- Expectations for Extending Issue Report Cause Investigations and Corrective Action Due Dates, Rev. 4 - EP-AA-120; Emergency Plan Administration, Rev. 14
- EP-AA-120-1001; 50.54(q) Program Evaluation and Effectiveness Review, Rev. 6
- HU-AA-101; Human Performance Tools and Verification Practices, Rev. 5
- HU-AA-102; Technical Human Performance Practices, Rev. 6
- LS-AA-120; Issue Identification
and Screening Process, Rev. 14
- LS-AA-125; Corrective Action Program Procedure, Rev. 16
- LS-AA-125-1001; Root Cause Analysis Manual, Rev. 8 - LS-AA-125-1002; Common Cause Analysis Manual, Rev. 7
- LS-AA-125-1003; Apparent Cause Evaluation Manual, Rev. 10
- LS-AA-126; Self-Assessment
Program, Rev. 6
- LS-AA-1400; Event Reporting Guidelines 10 CFR 50.72 and 50.73, Rev. 4
- OP-AA-103-102; Watch Standing Practices, Rev. 8
Attachment
LIST OF ACRONYMS USE
D ACE Apparent Cause Evaluation
ATI Action Tracking Item
ADAMS Agencywide Document Access Management System
CA Corrective Action
CAP Corrective Action Program
CAPCO Corrective Action Program Coordinator
CAPR Corrective Action to Prevent Recurrence
CCA Common Cause Analysis
CFR Code of Federal Regulations
DRP Division of Reactor Projects
EAL Emergency Action Level
IP Inspection Procedure
IR Issue Report
LER Licensee Event Report
MRC Management Review Committee
NCV Non-Cited Violation
NOV Notice of Violation
NPF Nuclear Power Facility
NRC U.S. Nuclear Regulatory Commission
PARS Publicly Available Records
System RCE Root Cause Evaluation
SL Severity Level
SOC Station Ownership Committee
M. Pacilio
-2- 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/
Eric
- R. Duncan, Chief Branch 3 Division of Reactor Projects
Docket No.
50-456; 50-457 License No.
Enclosure:
Inspection Report 05000456/2011013; 05000457/2011013
w/Attachment: Supplemental Information
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OFFICE RIII NAME EDuncan:dtp
DATE 0 1/17/12 OFFICIAL RECORD COPY
Letter to M. Pacilio from
- E. Duncan dated January 17, 2012.
SUBJECT: BRAIDWOOD STATION - NRC FOLLOW UP INSPECTION REPORT 05000456/2011013; 05000457/2011013
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