IR 05000331/2009007

IR 05000331-09-007; (May 5, 2009 - May 22, 2009), Duane Arnold Energy Center; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML091770606
Person / Time
Site:	Duane Arnold
Issue date:	06/26/2009
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	Richard Anderson Duane Arnold
References
IR-09-007
Download: ML091770606 (30)

Text

une 26, 2009

SUBJECT:

DUANE ARNOLD ENERGY CENTER PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000331/2009007

Dear Mr. Anderson:

On May 22, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at the Duane Arnold Energy Center. The enclosed report documents the inspection results, which were discussed on June 16, 2009, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspection concluded that your staff was effective at identifying problems and incorporating them into the corrective action program. In general, issues were appropriately prioritized, evaluated, and corrected, audits and self-assessments were thorough and probing, and operating experience was appropriately screened and disseminated. Your staff was aware of the importance of having a strong safety-conscious work environment and expressed a willingness to raise safety issues.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified which involved a violation of NRC requirements. However, because of the very low safety significance, and because the issue was entered into the corrective action program, the NRC is treating this issue as a non-cited violation (NCV) in accordance with Section VI.A.1 of the NRC Enforcement Policy.

If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Duane Arnold Energy Center. In addition, if you disagree with the characterization of the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Duane Arnold Energy Center. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

Sincerely,

/RA/

Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-331 License No. DPR-49 Enclosure: Inspection Report 05000331/2009007 w/Attachment: Supplemental Information cc w/encl: M. Nazar, Senior Vice President and Chief Nuclear Officer M. Ross, Vice President and Associate General Counsel A. Khanpour, Vice President, Nuclear Engineering D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs M. Mashhadi, Senior Attorney T. Jones, Vice President, Nuclear Operations, Midwest Region P. Wells, Vice President, Safety Assurance R. Hughes, Director, Licensing and Performance Improvement D. McGhee, Iowa Dept. of Public Health Chairman, Linn County, Board of Supervisors R. McCabe, Chairman, Regional Assistance Committee, DHS/FEMA Region VII M. Rasmusson, State Liaison Officer

SUMMARY OF FINDINGS

IR 05000331/2009007; (May 5, 2009 - May 22, 2009), Duane Arnold Energy Center; Biennial

Baseline Inspection of the Identification and Resolution of Problems.

This team inspection was performed by two regional inspectors, a resident inspector and the site resident inspector. Based on the results of this inspection, one Green finding was identified by the inspectors and is considered to be a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems Overall the corrective action program (CAP) program was adequate in that issues were identified at a low threshold, evaluated and corrected. Self-assessments and audits by Nuclear Oversight (NOS) were thorough and critical of the assessed areas. Operating experience was recognized as valuable, was appropriately evaluated, and was effectively communicated in daily plant meetings and pre-job briefings. Interviews with licensee staff and a review of the employee concerns program indicated that the licensee had a positive safety culture environment that encouraged identification of issues in the CAP.

However, the inspectors identified several areas of concern that prevented the CAP from being an effective tool for performance improvement. There were examples where licensee staff failed to demonstrate a challenging, questioning attitude during issue screening and evaluation, where identified program weaknesses or vulnerabilities were accepted without a strong desire for change, and where management expectations were not reinforced. For example:

• Ineffective trending has been a recurring issue since 2005, based on the results of NRC, industry and station assessments. However, fixing this problem does not appear to be a station priority. Although the pieces needed to have a successful program are largely in place, there does not appear to be a drive to actually implement the process.

• There were some examples of CAP issues that were inappropriately challenged either at the Initial Screening Team (IST), Management Review Committee (MRC) or both. The inspectors observed instances where IST and MRC members accepted issues without challenging the information given or considering the overall impact of the issue on the safety/risk function of the component or system.

• There was a tendency to perform myopic reviews focusing on the specific issue being evaluated and not on the underlying performance concern. Standards for performing cause evaluations were not being reinforced. There were several examples where the review of extent of condition, applicability of operating experience or the basis for the conclusion were either limited or not well documented. Although some of the issues were identified during the evaluation grading, there was no priority or impetus to change the incorrect behavior.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified by the inspectors for a failure of the licensee to promptly identify and correct a condition adverse to quality (CAQ) associated with the D river water supply (RWS) pump mounting base bolted connectors. The licensees failure to evaluate the operability of the D RWS pump due to the degraded bolting was considered a performance deficiency. By not examining the thread degradation documented on the overtorqued D RWS pump mounting base bolted connectors, the licensee was unable to adequately identify the as-left condition of the stud threads, evaluate the impact that condition had on the seismic qualification of the pump, and implement appropriate corrective actions to resolve the degraded condition. The failure to promptly identify and correct a CAQ associated with the safety-related D RWS pump was a violation of NRC requirements specified in 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action. The licensee entered this issue into the Corrective Action Program (CAP Item 067412),

examined the pump mounting connectors, and initiated a prompt operability determination to evaluate the seismic qualification. Based on this evaluation, the D RWS pump was declared Operable but degraded.

The performance deficiency was determined to be more than minor because the issue was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated this finding using the Significance Determination Process (SDP) and determined the finding was of very low safety significance (Green) because this finding was a design or qualification deficiency that did not result in a loss of operability of the safety component. The inspectors also determined that this finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because the licensee did not promptly and completely identify an adverse condition in the CAP in a timely manner commensurate with its safety significance. P.1(a). (Section 4OA2.1b.(1))

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

Problem Identification and Resolution (PI&R) as defined in IP 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees corrective action program (CAP) implementing procedures and attended CAP program meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC PI&R inspection in April 2007. The selection of issues ensured an adequate review of issues across the NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed CAP items generated as a result of facility personnels performance in daily plant activities. The inspectors also reviewed CAP items and a selection of completed investigations from the licensees various investigation methods, including root, apparent and common cause evaluations.

The inspectors performed a more extensive review of the risk significant river water supply systems and the station operational decision making (ODMI) process. The review of the river water system consisted of a five year search of related issues identified in the CAP and discussions with appropriate licensee staff to assess the licensees efforts in addressing identified concerns.

During the reviews, the inspectors evaluated whether the licensee staffs actions were in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors evaluated if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues.

The inspectors also evaluated whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including NCVs.

b. Assessment

(1) Effectiveness of Problem Identification Overall the CAP program was adequate in that issues were identified at a low threshold, evaluated and corrected. Workers were encouraged to identify issues and were familiar with the various avenues available (NRC, CAP, etc). This was evident by the large number of CAP items generated annually, which were reasonably distributed across the various departments. A shared computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response. This included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.

However, there were some areas of concern that prevented the CAP from being an effective tool for performance improvement. There were examples where licensee staff failed to demonstrate a challenging, questioning attitude during issue screening and evaluation and where identified program weaknesses or vulnerabilities were accepted without a strong desire for change. Some specific examples were:

• The inspectors observed an IST meeting reviewing CAP Issue Reports 67034 and 67028, involving foreign material found in the condensate storage tank. Both issues were screened as conditions not adverse to quality (NCAQ) on the basis that the tank was non-safety related. However, the IST failed to consider the impact the foreign material could have on the safety related high pressure core injection system, which takes suction from the CST during the initial stage of a design-basis accident.

• The inspectors observed the MRC screening of CAP Issue Report 66544, regarding the potential overtorquing of the D river supply pump mounting bolts. Although the report did not contain sufficient information to determine whether the pump was adequately mounted, this issue was not identified during the MRC screening. The pump is safety-related and is required to remain available during a seismic event.

• Corrective Action Program Report 63741, was not considered a condition adverse to quality (CAQ) even though it identified potential degradation of cabling associated with the high pressure core injection, main steam isolation valves and reactor core isolation systems (all safety-related and/or risk significant systems). The issue had been identified during the 2009 refueling outage and was screened by the MRC.

Other examples were also identified by the team and were discussed with licensee staff.

The licensee initiated CAP Reports 67083 and 67412 for the above examples.

Ineffective trending has been a recurring issue since 2005, based on the results of NRC, industry and station assessments. However, fixing this problem does not appear to be a station priority. Although the pieces needed to have a successful program are largely in place, there does not appear to be a drive to actually implement the process. The inspectors observed the following:

• There was no stated expectation or procedural guidance regarding when to issue a trend (i.e., a minimum threshold);

• From May 2008 to May 2009, over 9100 items were issued into the CAP, yet only 24 trend CAPs were initiated. Of these, 12 came from Operations and at least one from NRC; and

• Some CAP evaluations (apparent cause evaluation (ACE) 1776, CAP 59216) had identified recurring events, yet there was no discussion or action to consider a common-cause evaluation.

This licensee initiated CAP Report 67330 for the issues with the trend program.

The inspectors also noted that the licensees procedures didnt state how risk significant, but non-safety related issues were classified. Specifically, the CAP procedures precluded these issues as being either CAQs or NCAQs, based on the specific definitions of these terms. Licensee staff was conditioned to classify only safety-significant issues as CAQs and all non-safety issues as NCAQs, regardless of risk significance. For example, CAP Report 63613, concerning degraded cabling for the main generator protection logic and turbine electro-hydraulic control systems, was screened as an NCAQ, but there was no documentation of whether the issue was risk significant or a potential plant reliability concern. The licensee initiated CAP Report 67361 to address this issue.

The inspectors identified that contrary to ACP 1410.12, Operator Burden Program, Rev. 16, (Section 3.2(4)), the Operations Manager was not presenting the status of the operator burden program to the plant health committee on a monthly basis. The licensee initiated CAP Report 67440 to address this issue.

Findings Failure to promptly identify and evaluate the degraded condition associated with the D RWS pump mounting base bolted connectors

Introduction:

A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified by the inspectors for a failure of the licensee to promptly identify and correct a condition adverse to quality associated with the safety-related D RWS pump.

Description:

On April 5, 2009, the D RWS pump tripped approximately 30 seconds after being started from the control room. The pump was declared inoperable and an investigation commenced. The pump was found to be mechanically bound, with the motor supply breaker tripped on an over-current condition. A work request card (CWO A96711) was written and formal troubleshooting started.

On April 7 the D RWS pump was removed from the intake structure for repair. The pump was re-installed on April 13. The work was done, in accordance with the equipment-specific maintenance procedure, PUMP-J105-03, Aurora/Johnston River Water Pumps, Revision 9. In accordance with this procedure, the pump mounting and discharge head flange bolts were torqued to 424-464 ft-lbs.

During post-maintenance testing, the pump experienced high vibration readings, requiring removal and reinstallation of the pump bolts. During the reinstallation, one of the six bolts failed and the threads were stripped. The work was stopped and CAP Report No. 066544, was initiated. The CAP stated that one of the studs had stripped and that the other five studs were showing signs of thread degradation.

The licensee identified that the actual, installed bolts (per the construction drawings)differed from those referenced in the maintenance procedure. This meant that the torque value stated in the procedure (424-464 ft-lbs) was incorrect. The correct value (based on the actual bolts installed) was 190-210 ft-lbs. Therefore, the pump mounting and discharge head flange bolts had been overtorqued.

The stripped stud was repaired and the remaining five studs were re-torqued to the correct value. However, these studs were not removed or inspected for thread degradation prior to being re-torqued. Following post-maintenance testing, the pump was declared operable on April 17 and the CWO was closed. A procedural change request was initiated to change the referenced torque value in the pump maintenance procedure.

Corrective Action Program 066544 was reviewed by the MRC on April 16. The issue was properly characterized as a condition adverse to quality and the Engineering Department was tasked to perform a condition evaluation (CE 7353) addressing the extent of condition of the other RWS pumps. The completed CE was reviewed by the MRC on May 19. The MRC approved the CE, as documented, with no additional questions or changes. The inspectors noted that while the CE adequately addressed the condition of the other RWS pumps, it did not address the overtorquing of the five remaining studs on the D RWS pump, specifically, whether any thread degradation had occurred which may impact the pump operability. The inspectors asked to review the documentation of the condition of the remaining five studs, specifically, whether the seismic qualification for the D RWS pump was still within design bases. The licensee stated a visual examination of the studs was performed by the mechanical maintenance personnel during the final pump re-assembly and that the only documentation was the description in CAP 66544. The licensee also stated that an evaluation of the seismic qualification of the pump mounting had not been performed. The licensee initiated CAP 67412 to address the inspectors concerns.

Subsequently, the Shift Manager requested a prompt operability determination from the engineering department and the licensee initiated a work order (CWO A101663) to inspect and document the actual condition of the D RWS pump mounting studs. The inspection identified no cracks, but found that all of the studs had from 3 to 5 degraded threads on each stud, amounting to anywhere from 100 percent (no thread available for engagement) to 25 percent of the thread missing. A subsequent licensee evaluation identified that the degradation significantly challenged the ability of the studs to meet the original design basis stress limits during either an operational or a design basis earthquake. Since calculations showed that the mounting stud threads would still meet the Appendix F ASME Section III code maximum allowable values, the D RWS pump was declared Operable but degraded. A CAP item was initiated (OBD 000317) to ensure that the studs would be repaired no later than the next refueling outage.

Analysis:

The licensees failure to evaluate the operability of the D RWS pump due to the degraded bolting was considered a performance deficiency. By not performing this evaluation, the licensee failed to recognize that the affected studs had significant thread wear, and required replacement in order to restore the pump to full operability.

Traditional enforcement did not apply since there were no actual safety consequences or potential for impacting the NRCs regulatory function, and the finding was not the result of any willful violation.

The performance deficiency was more than minor because the issue was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, by not examining the thread degradation documented on the overtorqued D RWS pump mounting base bolted connectors, the licensee was unable to adequately evaluate the impact the condition had on the seismic qualification of this safety-related component. The inspectors evaluated this finding using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of findings, Table 4a for the Mitigating Systems cornerstone. Since this finding is a design or qualification deficiency that did not result in a loss of operability of the safety component, the finding was determined to be of very low safety significance (Green).

The failure to accurately and completely characterize the actual as-left condition of the studs precluded the ability to evaluate the potential impact the condition had on the seismic qualification of the safety-related component. The inspectors determined that this finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because the licensee did not promptly and completely identify an adverse condition in the CAP in a timely manner commensurate with its safety significance. P.1(a)

Enforcement:

The 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, between April 14, 2009, and May 19, 2009, the licensees initial identification, screening, evaluation, and implemented corrective actions associated with the over-torquing of the D RWS pump mounting base bolted connectors, failed to promptly identify and correct a condition adverse to quality regarding the seismic qualification of safety related components. Specifically, by not examining the thread degradation documented on the overtorqued D RWS pump mounting base bolted connectors, the licensee was unable to adequately identify the as-left condition of the stud threads, evaluate the impact that condition had on the seismic qualification of the pump, and implement appropriate corrective actions to resolve the degraded condition.

Once this issue was identified by the inspectors, the licensee entered this issue into the CAP, examined the pump mounting connectors, and initiated a prompt operability determination to evaluate the seismic qualification. The D RWS pump was subsequently declared Operable but degraded and a CAP tracking item was initiated to return the pump to the fully operable condition.

Because this violation was of very low safety significance and issue was entered into the licensees CAP, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000331/2009007-01).

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors observed that the majority of issues were of low level and were either closed to trend or at a level appropriate for a condition evaluation. Some of these issues were closed to a work request or to another CAP report, but the inspectors noted that both the parent and daughter documents had the necessary verbiage to document the interrelationship. Although fewer in number, the inspectors did not have any concerns with those issues assigned an ACE or root cause evaluation. There were no items in the operations, engineering, or maintenance backlogs that were risk significant, individually or collectively. The inspectors also identified no issues during the review of the ODMI process.

The inspectors observed that standards for performing cause evaluations were not being reinforced. There were several examples where the review of the extent of condition, applicability of operating experience, or the basis for the conclusion were either limited or not well documented. There was a tendency to perform myopic reviews focusing on the specific issue being evaluated rather than the underlying performance concern.

• Apparent Cause Evaluation 1922 was written to investigate higher than expected dose rates in the radwaste surge tank following a water transfer. Although the ACE identified some issues with how water transfers were conducted in general, it only focused on the specific circumstances. Additionally, the ACE failed to consider whether previously identified operating experience could have prevented this event.

• Apparent Cause Evaluation 1833 was written to investigate why one security crew did not have the necessary fire brigade trained personnel. Although the ACE identified a similar, prior event, there was no discussion of why the corrective actions from that event failed to prevent recurrence.

• Apparent Cause Evaluation 1776 was written to investigate why a degraded cable issue had not been captured in the CAP. However, the ACE did not evaluate this issue, but only addressed the operability impact of the degraded cable. Additionally, the ACE identified several, similar prior events, but did not evaluate whether a common-cause evaluation was warranted.

• Apparent Cause Evaluation 1780 was written to investigate an unposted high radiation area identified on the torus catwalk. The ACE had a very limited extent-of-condition evaluation and failed to consider whether previously identified operating experience could have prevented this event.

• Apparent Cause Evaluation 1802 was written to investigate events where operating crews failed to maintain critical parameters within prescribed limits. The extent of condition was limited to a listing of internal operating experience and did not address other areas of plant operations where a similar condition could exist.

Each of the above ACEs had been graded by the respective, initiating departments prior to issuance. In some cases, these issues were identified during the grading, but there was no expectation or impetus to change the incorrect behavior, as the ACEs received passing scores. The licensee initiated CAP Reports 67100, 67307, and 67331 to address the issues identified by the inspectors.

Corrective Action Program Report 58355 was initiated after the licensee identified that the B standby diesel generator lube oil temperature was high due to a failed switch.

The MRC concluded that an ACE was not required as the cause of the issue was simple and known and that the extent of condition was understood. However, the inspectors noted that there was no causal analysis regarding why the switch failed. The licensee initiated CAP Report 58355 to evaluate why the cause of the switch failure was not evaluated.

Findings No findings of significance were identified.

(3) Effectiveness of Corrective Actions The inspectors concluded that over the 2 year period encompassed by the inspection, the licensee implemented effective corrective actions. The inspectors identified no significant examples where problems recurred.

However, the inspectors identified some examples where issues identified in CAP evaluations were not fully addressed by corrective actions. For example:

• Root cause evaluations 1074 and 1075 addressed weaknesses in the CAP program identified by an industry audit. The evaluations identified several items of concern, yet there were no clearly identified corrective actions associated with each of these items.

• Corrective Action Program Report 62896 was written to address an unexpected alarm on an average power range monitor (APRM) due to age related degradation of a relay. Although the CAP evaluation identified other, similar relays susceptible to similar failure in the APRM system (which was safety-related), there were no corrective actions to evaluate the plant risk in order to prioritize repairs.

The above examples were due, in part, to the issues with the quality of the cause evaluations discussed above, and will be addressed in the associated CAP report items.

However, the licensee did initiate CAP Report 67237 to evaluate the issues with root cause evaluations 1074 and 1075.

The inspectors also identified numerous examples where extensions for corrective actions were granted without having an adequate basis or documenting the justification.

The licensee issued CAP Report 65894 to address this issue.

Findings No findings of significance were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, observed daily station and pre-job briefings to observe the use of OE information, and reviewed completed evaluations of OE issues and events. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

b. Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.

Findings No findings of significance were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.

b. Assessment The inspectors considered the quality of the NOS audits to be thorough and critical. The self-assessments were acceptable but, as expected, they were not at the same level of quality as the audits. The inspectors observed that CAP items had been initiated for issues identified through the NOS audits and self-assessments.

The inspectors identified that the maintenance department, contrary to the other plant departments, had not performed a quick-hit self-assessment in the past 2 years. The licensee initiated CAP Report 67376 to address this issue.

Findings No findings of significance were identified.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety-conscious work environment through the reviews of the facilitys ECP implementing procedures, discussions with ECP coordinators, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results of licensee safety culture surveys.

The inspectors reviewed the following ECP case files (titles redacted): 09-06R, 06-03, 07-06,07-03R, 08-05, 08-08, and 08-02. These files involved potential cases of harassment and intimidation for raising safety issues.

b. Assessment The inspectors determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP process.

These results were similar with the findings of the licensees safety culture surveys.

Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.

The inspectors determined that the ECP process was being effectively implemented.

The inspectors review of several, selected case files (generated from 2006-2009)concerning apparent cases of harassment and intimidation for raising safety concerns determined that the licensee had appropriately investigated and taken effective action to address the individual issues and promote a strong SCWE. However, during the interviews, several individuals did not know who the site ECP coordinator was nor were familiar with the site Differing Professional Opinion process (which was another forum, similar to the ECP, for raising safety issues). The inspectors also identified a potential vulnerability in the ECP process based on how issues were classified. Specifically, the inspectors noted that based on the classification, some issues had more relaxed requirements regarding documentation and feedback to the originator which may lead individuals to believe that the ECP was not effectively addressing issues. The licensee initiated CAP Report 67378 to address this concern.

Findings No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

• On May 22, 2009, the inspectors presented the inspection results to Mr. Anderson and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

• On June 16, 2009, the inspectors held a teleconference with Mr. Anderson and other members of his staff, to discuss the finding and NCV for the failure to identify and correct a CAQ associated with the D RWS pump.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Anderson, Site Vice President

R. Murrell, Licensing Engineer

D. Brigl, Employee Concerns Investigator

S. Catron, Licensing Manager

D. Curtland, General Plant Manager

M. Davis, Emergency Preparedness Manager

P. Dutcher, Maintenance Support General Supervisor

P. Giroir, Operations Support Manager

B. Porter, Radiation Protection/Chemistry Manager

G. Rushworth, Assistant Operations Manager

J. Schwertfeger, Security Operations Supervisor

J. Swales, Mechanical Design Supervisor

• Present during the June 16, 2009, teleconference

Nuclear Regulatory Commission

K. Riemer, Chief, Branch 2, Division of Reactor Projects

LIST OF ITEMS

Opened and Closed

05000331/2009007-01 NCV Failure to promptly identify and evaluate the degraded condition associated with the D RWS pump mounting base bolted connectors (Section 4OA2.1b.(1))

Attachment