IR 05000413/2020011

Biennial Problem Identification and Resolution Inspection Report 05000413/2020011 and 05000414/2020011 Dated December 18, 2020

ML20353A066
Person / Time
Site:	Catawba
Issue date:	12/18/2020
From:	Margaret Tobin NRC/RGN-II
To:	Simril T Duke Energy Carolinas
References
IR 2020011
Download: ML20353A066 (15)

Text

December 18, 2020

SUBJECT:

CATAWBA NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2020011 AND 05000414/2020011

Dear Mr. Simril:

On November 20, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Catawba Nuclear Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Margaret C. Tobin, Acting Chief Reactor Projects Br #1 Div of Reactor Projects Docket Nos. 05000413 and 05000414 License Nos. NPF-35 and NPF-52

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000413 and 05000414 License Numbers: NPF-35 and NPF-52 Report Numbers: 05000413/2020011 and 05000414/2020011 Enterprise Identifier: I-2020-011-0023 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station Location: York, SC Inspection Dates: November 02, 2020 to November 20, 2020 Inspectors: R. Cureton, Resident Inspector D. Mas-Penaranda, Project Engineer C. Scott, Resident Inspector, Team Lead J. Worosilo, Senior Project Engineer Approved By: Margaret C. Tobin, Acting Chief Reactor Projects Br #1 Div of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Catawba Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program (CAP), use of operating experience, self-assessments and audits, and safety conscious work environment.

• Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted an in-depth CAP review of the residual heat removal system, chemical volume and control, emergency supplemental power system, and the safety injection system.

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

• Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B 1. Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure AD-PI-ALL-0100, "Corrective Action Program," and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.

Problem Prioritization and Evaluation: Based on the review of condition reports, the inspectors concluded that problems were prioritized and evaluated in accordance with the condition report significance determination guidance in procedure AD-PI-ALL-0100. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed condition reports and effectiveness reviews to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.

2. Operating Experience

The inspectors determined that the station's processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.

3. Self-Assessments and Audits

The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.

Self-assessments were generally detailed and critical. The inspectors verified that condition reports (CRs) were created to document areas for improvement and findings resulting from self-assessments, and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.

4. Safety Conscious Work Environment

Based on interviews with plant staff and reviews of the latest safety culture survey results to assess the safety conscious work environment on site, the inspectors found no evidence of challenges to the safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

Observation: Self-Assessments and Audits 71152B During the inspection, the team reviewed licensee procedure AD-EG- ALL-1002, Conduct of Design Engineering. AD-EG- ALL-1002, Section 5.6 Management of Corrective Action EC Backlog, requires that a review of open engineering changes to correct conditions adverse to quality be performed between the months of June and August each year. The purpose of the review is to confirm that the age and implementation date for the engineering change (EC) is timely and acceptable for addressing the adverse condition at the plant. This review is required to be documented in a self-assessment report and presented to the plant health committee. When the team requested copies of the self-assessments, the licensee discovered that the 2020 self-assessment had not been performed as required by procedure. Catawba entered this issue in the CAP as CR 2358656 and initiated actions to perform a self-assessment of the EC backlog in 2020. The licensee performed a cursory review of the open ECs and verified that the ECs for risk significant equipment were tracked by either a condition adverse to quality (CAQ) work order in the work management system or a CAPR in the CAP program. The team concluded that even though the self-assessment was not performed, the licensee demonstrated that the schedule dates for the open ECs were appropriate for addressing the conditions adverse to quality.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On November 20, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Tom Simril and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action NCRs 1897267

Documents 2161152

205072

23943

24847

26880

29344

29571

230620

233672

235304

236600

239553

244942

245845

246958

247876

249561

256331

256868

257769

264322

265962

270638

271394

275149

278168

279736

280631

280660

288734

288755

Inspection Type Designation Description or Title Revision or

Procedure Date

290100

290319

290522

293014

293228

293620

293759

294307

294574

294614

295296

297177

299143

299984

2300383

2300922

2302424

2302472

2303441

2305450

2308405

2314730

2319066

2319620

20233

29426

2331304

2331792

2337921

2338939

2340429

2348493

2349025

2349344

Inspection Type Designation Description or Title Revision or

Procedure Date

2349784

2351604

27287

275467

24404

2330654

292867

283390

2311992

279376

290855

288606

280118

2309023

252082

2316312

2308530

291848

259146

292063

282910

2319975

2310713

242969

297129

290339

29632

243702

241973

299936

2311354

2334670

2335989

2348355

Inspection Type Designation Description or Title Revision or

Procedure Date

2319532

290528

295170

1496462

2061998

2315936

287546

270638

290522

21754

21302

22033

22346

22499

22579

212222

260624

257482

2303601

2303697

2303851

26580

216962

247837

2338327

296571

247832

284178

2351299

2355996

2350661

214326

277988

2184291

Inspection Type Designation Description or Title Revision or

Procedure Date

22339

29433

292605

29335

278487

292371

292736

244992

249421

26633

2346486

2352344

2342017

2314994

2341330

27594

22339

1945732

29433

237293

2184291

2342917

2315936

275149

2192509

22346

247779

2331304

2346908

295850

247749

231525

250289

28507

Inspection Type Designation Description or Title Revision or

Procedure Date

26532

230608

247603

296571

2335856

Corrective Action NCRs 2358656

Documents

Resulting from

Inspection

Procedures AD-PI-ALL-0400 Operating Experience Program Revision 8

AD-EG-ALL-1202 Preventive Maintenance and Surveillance Testing Revision 9

Administration

AD-EG-ALL-1209 System Health and Notebooks Revision 8

AD-EG-ALL-1210 Maintenance Rule Program Revision 2

AD-NO-ALL-0202 Employee Concerns Program Revision 3

AD-OP-ALL-0105 Operability Determinations Revision 3

AD-PI-ALL-0100 Corrective Action Program Revision 24

AD-PI-ALL-0106 Cause Investigation Checklists Rev.4

AD-PI-ALL-0300 Self-Assessment and Benchmark Programs Revision 4

AD-PI-ALL-0401 Significant Operating Experience Program Revision 8

AD-PI-ALL-101 Root Cause Evaluation Revision 7

AD-QC-ALL-1000 CONDUCT OF NUCLEAR OVERSIGHT QUALITY Revision 9

CONTROL

IP/0/B/4974/059 Main Generator and Exciter PM Inspection 02,03

MP/0/A/7150/097 Standby Makeup Pump Suction Pulsation Damper 19,20,21

Preventative Maintenance Inspection

TE-MN-ALL-0202 Transformer and Apparatus Testing

Work Orders 20297426

297432

297528

298165

299678

20313089

20313638

Inspection Type Designation Description or Title Revision or

Procedure Date

20325390

20345446

20356110

20162010

2