IR 05000369/2016007

McGuire Nuclear Station - NRC Problem Identification and Resolution Inspection Report 05000369/2016007 and 05000370/2016007, May 2-6, 2016 and May 16-19, 2016

ML16173A338
Person / Time
Site:	Mcguire, McGuire
Issue date:	06/21/2016
From:	Masters A D Reactor Projects Branch 7
To:	Capps S D Duke Energy Carolinas
References
IR 2016007
Download: ML16173A338 (15)

Text

June 21, 2016

Mr. Steven Site Vice President Duke Energy Carolinas, LLC McGuire Nuclear Station MG01VP/12700 Hagers Ferry Road Huntersville, NC 28078

SUBJECT: MCGUIRE NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000369/2016007 AND 05000370/2016007

Dear Mr. Capps:

On May 19, 2016, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at McGuire Nuclear Station Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on May 19, 2016, with Mr. and other members of your staff.

Based on the inspection samples, the inspectors determined that your staff's implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the inspectors assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the inspectors determined that your staff's performance was adequate to support nuclear safety.

The inspectors also evaluated other processes your staff used to identify issues for resolution. These included your staff's use of audits and self-assessments to identify latent problems and incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The inspectors determined that your station's performance in each of these areas supported nuclear safety.

Finally, the inspectors determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the inspectors' observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available.

On the basis of the samples selected for review, the inspectors concluded that in general, problems were properly identified, evaluated, and corrected. The NRC inspectors did not identify any findings or violations of more than minor significance. On the basis of the samples selected for review, the inspectors concluded that in general, problems were properly identified, evaluated, and corrected. In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Anthony D. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects

Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17

Enclosure:

IR 05000369/2016007 and 05000370/2016007

w/Attachment:

Supplemental Information

SUMMARY OF FINDINGS

05000369/2016007 and 05000370/2016007; May 2

May 16-19, 2016; McGuire Nuclear Station, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by one senior project inspector, two resident inspectors, and a reactor inspector. The significance of most findings is identified by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP); cross-cutting aspects were determined using IMC 0310; Aspects Within Cross-Cutting Areas; and findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5. Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.

The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensee's processes for performing and managing work, and plant operations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed the licensee's Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (NCRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed NCRs that had been issued between June 2014 and May 2016, including a detailed review of selected NCRs associated with the following risk-significant systems: Auxiliary Feedwater, Component Cooling, Residual Heat Removal, and Nuclear Service Water. Where possible, the team independently verified that the corrective actions were implemented as intended. The team also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the team selected a representative number of NCRs that were identified and assigned to the major plant departments, including health physics, chemistry, emergency preparedness and security. These NCRs were reviewed to assess each department's threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected NCRs, verified corrective actions were implemented, and attended meetings where NCRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold. Plant walk-downs of equipment within the selected systems listed above and other plant areas were conducted by inspectors to assess the material condition and to identify deficiencies that had not been previously entered into the CAP. The inspectors reviewed NCRs, maintenance history, corrective actions (CAs), completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-related issues. Control Room walk-downs were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected NCRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the NCRs and the guidance in licensee procedures AD-PI-ALL-0102, Apparent Cause Evaluation and AD-PI-ALL-0101, Root Cause Evaluation.

The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRC's assessment of the licensee's CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. NCR screening meetings and Management Review Committee (MRC) meetings.

Documents reviewed are listed in the Attachment.

b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating NCRs as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program, management's expectation that employees were encouraged to initiate NCRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walk-downs of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP. Problem Prioritization and Evaluation Based on the review of NCRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the NCR significance determination guidance found in AD-PI-ALL-0100. The inspectors determined that in general, adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensee's CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate NCRs depending on the type and complexity of the issue consistent with licensee procedures AD-PI-ALL-0101, Root Cause Evaluation, AD-PI-ALL-0102, Apparent Cause Evaluation, and AD PI ALL 0103, Quick Cause Evaluation.

The team identified one observation and one minor violation discussed below.

• The team evaluated Root Cause Evaluation M-14-9052 (NCR 1902040), "1B-1C NDE Cold Leg Safety Injection Line Indications." The team determined that the licensee's identification of a circumferential indication on the Unit 1 Cold Leg 1B and 3 axial indications on the Unit 1 Cold Leg 1C constitute two examples similar to the performance deficiency for a previous flaw indication on the Unit 2 Cold Leg 2D documented as a previous LIV in Integrated Inspection Report 05000369/2014003 and 05000370/2014003. The team determined that the licensee's corrective actions for the previous LIV were effective. The team also determined that the licensee's root cause evaluation was adequate, the associated piping has been replaced, and no further action is required.

• The team identified one minor violation of 10 CFR 50, Appendix B, Criterion V, for failure to follow procedure AD-OP-ALL-0105, "Operability Determinations and Functionality Assessments," Revision 2. Specifically, AD-OP-ALL-0105 states Operability Determinations and Functionality Assessments will be "consistent with NRC Inspection Manual Chapter 0326, Operability Determinations and Functionality Assessments for Conditions Adverse to Quality or Safety."

On March 23, 2016, licensee staff identified an indication in weld 1NC1F-1374 during a UT exam and determined that it did not meet the acceptability criteria in ASME Code (Code of Record: 2007 Edition, 2008 Addenda). McGuire performed an immediate determination of operability for Mode 6, and determined that even though the flaw was unacceptable by ASME Code, the piping would be fully capable of performing its safety function in Mode 6. This is not consistent with IMC 0326 which states in part: "When ASME Class 1 components do not meet ASME Code or construction code acceptance standards, the requirements of an NRC endorsed ASME Code Case, or an NRC approved alternative, then an immediate operability determination cannot conclude a reasonable expectation of operability exists and the components are inoperable."

The failure to follow procedure AD-OP-ALL-0105 resulted in Technical Specification (TS) 3.9.6, Action Statement A not being entered which requires immediate actions be taken to restore the required RHR loops to operable status. Based on the fact that the licensee performed the necessary repairs to restore the RHR loops to operable status in a timely manner without leaving Mode 6, and these actions were consistent with Action Statement A of TS 3.9.6, the team determined this was a minor violation of NRC requirements and not subject to enforcement in accordance with the NRC's Enforcement Policy. Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, NCRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

c. Findings

None

.2 Use of Operating Experience

a. Inspection Scope

The team examined the licensee's use of industry OE to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since June 2014, to verify whether the licensee had appropriately evaluated each notification for applicability to the McGuire Nuclear Station, and whether issues identified through these reviews were entered into the CAP.

Documents reviewed are listed in the Attachment.

b. Assessment Based on a review of selected documentation related to operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure as specified by licensee procedure AD-PI-ALL-0400, Operating Experience Program. In addition, operating experience was included in all apparent cause and root cause evaluations in accordance with licensee procedures AD-PI-ALL-0102 and AD-PI-ALL-0101.

c. Findings

No findings were identified.

.3 Self-Assessments and Audits

a. Inspection Scope

The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure AD-PI-ALL-0300, Self-Assessments and Benchmark Programs.

Documents reviewed are listed in the Attachment.

b. Assessment The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspector's independent review. The team verified that NCRs were created to document areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate.

c. Findings

No findings were identified.

.4 Safety-Conscious Work Environment

a. Inspection Scope

During the course of the inspection, the team assessed the station's safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

b. Assessment Based on the interviews conducted and the NCRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exits

On May 19, 2016, the inspectors presented the inspection results to Mr. S. Capps and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Capps, Site Vice President

C. Morris, Plant Manager

S. Snider, Engineering Manager

J. Robertson, Regulatory Affairs Manager

R. Pocetti, Performance Improvement Manager

J. Gabbert, Chemistry Manager

K. Kinard, Security Manager

S. Mooneyhan, Radiation Protection Manager

A. Goodman, Fleet Regulatory Affairs

L. Hentz, Regulatory Affairs Engineer

G. Murphy, Regulatory Affairs

J. Brady, Corporate Regulatory Affairs

G. Houser, Performance Improvement

T. Reames, Senior Reactor Operator

P. Roberson, System Engineer

S. LaPointe, System Engineer

T. Sigmon, System Engineer

NRC personnel

S. Rose, Chief, Branch 5, Division of Reactor Projects

J. Zeiler, Senior Resident Inspector

LIST OF REPORT ITEMS

Opened and Closed

None

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

Procedures:

AD-AD-ALL-0004, Fleet Standard Workday, Revision 8

AD-PI-ALL-0100, Corrective Action Program, Revisions 0 to 5

AD-PI-ALL-0101, Root Cause Evaluation, Revisions 1 and 2

AD-PI-ALL-0102, Apparent Cause Evaluation, Revisions 1 and 2

AD-PI-ALL-0103, Quick Cause Evaluation, Revisions 1 and 2

AD-PI-ALL-0201, Corrective Action Program (CAP) Trending, Revision 2

AD-PI-ALL-0300, Self-Assessment and Benchmark Programs, Revisions 1 and 2

AD-PI-ALL-0400, Operating Experience Program, Revisions 1 and 2

AD-EG-ALL-1202, Preventive Maintenance and Surveillance Testing Administration, Revision 2

AD-EG-ALL-1207, Plant Health Process, Revision 2

AD-EG-ALL-1209, System, Component, and Health Reports and Notebooks, Revision 3

AD-EG-ALL-1210, Maintenance Rule Program, Revision 0

AD-EG-ALL-1211, System Performance Monitoring and Trending, Revision 3

AD-EG-ALL-1213, System Walkdowns, Revision 2

AD-EG-ALL-1520, Transient Combustible Control, Revision 3

AD-EG-ALL-1620, Implementation of the Nuclear Welding Program, Revision 0

AD-LS-ALL-0003, NRC Audit and Inspection Activities, Revision 3

AD-NO-ALL-0202, Employee Concerns Program, Revision 1

AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Revisions 0 to 2

AD-OP-ALL-0202, Aggregate Operator Impact Assessment, Revision 1

AD-WC-ALL-0230, Seasonal Readiness, Revision 0

NSD 104, Material Condition/ Housekeeping and Seismic Concerns, Revision 39

NSD-122, Temporary Configuration Changes, Revision 7

NSD-203, Operability/Functionality, Revision 26

NSD-208, Problem Investigation Program (PIP), Revisions 40 and 41

NSD-313, Control of Transient Fire Loads, Revision 17

NSD-316, Fire Protection Impairment and Surveillance, Revision 17

NSD-317, Freeze Protection Program, Revision 5

IP/0/A/3090/010, Sealing Safety-Related Equipment outside Containment and Doghouses, Revision 32 IP/0/A/3090/021 WG, WG Loop Calibration and Operational Test, Revision 15 IP/0/A/3190/003 C, Inspection and Cleaning of Electrical Enclosures, Revision 11 IP/0/A/3190/030, Molded Case Circuit Breaker Inspection and Functional Test, Revision 47

MP/0/A/7400/092, Nordberg Diesel Engine Fuel Rack Maintenance, Revision 11

MCS-1390.01-00-0053, McGuire Nuclear Station Electrical Installation Specification Manual, Revision 17

PD-EG-ALL-1620, Nuclear Welding Program, Revision 0

WPM 503, Site Welding Activities, Revision 4

NCRs Initiated for NRC Questions:

2026271, 2016 NRC PI&R Inspection - NCR Referenced Incorrect Area

26612, 2016 NRC PI&R Inspection, Evaluate Change to QCE Action

2026576, 2016 NRC PI&R Inspection NCV Closeout didn't ID difference

2026703, 2016 NRC PI&R Inspection: Evaluate

AD-PI-ALL-100 Enhancement

2029029, 2016 NRC PI&R Inspection - ND Walkdown

2029802, Wood Still Installed Around Grout Pad in Unit 2 Aux Bldg

2030208, 2016 NRCPI&R Inspection, KC system Walkdown

2030222, 2016 NRC PI&R Inspection RN Walkdown Observations

2030346, 2016 NRC PI&R Inspection -- Light Fixture with Exposed Wire

2030655, 2016 NRC PI&R Inspection

2030651, Documentation of CA Walkdown - 2016 PI&R Inspection Related

2030659, 2016 PI&R Inspection Question

2030874,

MNS 2016 NRC PI&R, Class 1 Pipe Flaw Operability Determ.

Condition Reports

(NCRs):

1668794,

1671961,

1673357,

1673639,

1674789,

1675043,

1676347,

1676577,

1676644,

1677900,

1678025,

1678064,

1679462,

1680955,

1682453,

1682467,

1684001,

1684055,

1684188,

1686081,

1686797,

1690541,

1692005,

1695180,

1695267,

1695276,

1695333,

1696699,

1698341,

1698533,

1699766,

1900604,

1901436,

1901646,

1901732,

1901812,

1901893,

1901904,

1901919,

1902040,

1902178,

1902218,

1902332,

1902358,

1902392,

1902474,

1902475,

1902529,

1902547,

1902616,

1902704,

1902853,

1902863,

1902975,

1904573,

1929605,

1930023,

1931366,

1931412,

1931932,

1932266,

1934403,

1935341,

1935383,

1935861,

1936741,

1936760,

1941186,

1946452,

1947988,

1960411,

1960744,

1960762,

1961955,

1962690,

1962849,

1965239,

1965902,

1967496,

1973050,

1975461,

1987827,

2001950,

2005730,

2005731,

2005739,

2005812,

2005821,

2009770,

2012460,

2012574,

2013556,

2014334,

2015564,

2020823,

2026271,

2026576,

2026612,

2026703,

29029,

2029802,

2030208,

2030222,

2030346,

2030651,

2030655,

2030659,

2030874

Apparent Cause Evaluations:

1939310,

1941186,

1950897,

1902603,

19022616,

1935341,

1902358,

2013556

Root Cause Evaluations: M-14-10857, M-14-7424, M-14-9052, M-14-3153

Audits: 2015-MNS-DES-01, McGuire Fleet Design Control Audit

2015-MNS-OPS-01, McGuire Operations Functional Audit

2014-MNS-CAP-01, Nuclear Oversight Audit - McGuire Corrective Action

2-9 (INOS)(CAP)(MNS) - Independent Nuclear Oversight Audit - McGuire Corrective Action Program 2014 MNS NOS PORC Effectiveness (M-OR-14-01)

Self Assessments (SAST):

1902394,

01675038,

1685178,

1904026,

1906368,

1945438,

1963419,

1733205,

1935798,

1934364

Procedure

Revision Requests (PRR):

020112458,

01971509,

01971106,

01971104,

01971101,

01971095,

01971089,

01971087,

01971085,

01971084

Work Orders

(WO):

1943279,

2004286,

20008609,

20002048

Other Documents: Nuclear Service Water System (RN) Station Health Report: Q4-2015 Residual Heat Removal System (ND) Health Report Q1 2016 Control Room Deficiency Audit Report

MCS-1561.ND-00-0001, Design Basis Document for ND System ST3250 Station Health Reports - Auxiliary Feedwater System (CA) - Q4-2015