IR 05000413/2012008
| ML12347A249 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/12/2012 |
| From: | Hopper G Reactor Projects Branch 7 |
| To: | Henderson K Duke Energy Corp |
| References | |
| IR-12-008 | |
| Download: ML12347A249 (17) | |
Text
December 12, 2012
SUBJECT:
CATAWBA NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2012008 AND 05000414/2012008
Dear Mr. Henderson:
On November 8, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Catawba Nuclear Station, Units 1 and 2.
The enclosed inspection report documents the inspection results that were discussed on November 8, 2012, with Mr. Scott Batson and other members of your staff.
This inspection was an examination of activities conducted under your licenses as they relate to problem identification and resolution and compliance with the Commissions rules and regulations and the conditions of your licenses. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Catawba Nuclear Station was effective. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were generally used to identify problems and appropriate actions.
No findings were identified during this inspection. 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 (PARS) component of NRCs Agencywide Document Access and Management 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/
George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects
Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52
Enclosure:
Inspection Reports 05000413/2012008 and 05000414/2012008, w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 050000413, 05000414
Report Nos.: 05000413/2012008, 05000414/2012008
Licensee:
Duke Energy Carolinas, LLC
Facility:
Catawba Nuclear Station, Units 1 and 2
Location:
York, SC 29745
Dates:
October 22 - November 8, 2012
Inspectors:
E. Stamm, Senior Reactor Inspector (Team Leader)
N. Staples, Senior Project Inspector R. Taylor, Senior Project Inspector J. Quinones, Project Engineer J. Worosilo, Project Engineer
Approved by: George T. Hopper, Chief
Reactor Projects Branch 7
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000413/2012-008 and 05000414/2012-008; 10/22/2012 - 11/8/2012; Catawba Nuclear
Station, Units 1 and 2; Problem Identification and Resolution Inspection.
This inspection was conducted by a team of five Nuclear Regulatory Commission (NRC)inspectors from Region II. No violations were identified during this inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, (ROP) Revision 4.
Problem Identification and Resolution
The team concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was generally effective at identifying problems and entering them into the corrective action program (CAP) for resolution. Generally, prioritization and evaluation of issues, formal root cause evaluations for significant problems, and corrective actions specified for problems were consistent with licensee CAP procedures. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The team determined that 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 licensees processes for performing and managing work, plant operations, and cause evaluations.
Based on discussions and interviews conducted with plant employees from various departments, the team determined that personnel at the site felt free to raise safety concerns to management and to use the CAP to resolve those concerns.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a.
Assessment of the Corrective Action Program
- (1) Inspection Scope
The team reviewed the licensees corrective action program (CAP) procedures, which described the administrative process for initiating and resolving problems primarily through the use of the Problem Identification Program (PIP). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the team reviewed PIPs that had been issued between November 2010 and October 2012, including a detailed review of selected PIPs associated with the following risk-significant systems: Chemical Volume and Control System (NV); Reactor Coolant System (NC); and 4160V and 600V Essential Auxiliary Power Systems. 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 to determine if they had been appropriately addressed. The team selected a representative number of PIPs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, emergency preparedness, health physics, and security to ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process. These PIPs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected PIPs, verified corrective actions were implemented, and attended meetings where PIPs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The team conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The team reviewed PIPs, maintenance history, completed work orders for the systems, and 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; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
The main control room deficiency list was reviewed to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator Workarounds and Operator Burden screenings were reviewed, and the team verified compensatory measures for deficient equipment were being implemented in the field.
The team conducted a detailed review of selected PIPs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The team reviewed these evaluations against the descriptions of the problems described in the PIPs and the guidance in licensee procedure NSD 212, Cause
Analysis.
The team 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 team reviewed selected industry operating experience 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 team reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The team attended various plant meetings to observe management oversight functions of the corrective action process.
Documents reviewed are listed in the Attachment.
- (2) Assessment
Identification of Issues
The team determined that the licensee was generally effective in identifying problems and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating PIPs as described in licensee procedure NSD 208, Problem Investigation Program, which stated the management expectation that employees were responsible for having a low threshold for identifying issues and reporting issues through timely PIP initiation. 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 walkdowns of accessible portions of the selected systems, the team determined that system deficiencies were being identified and placed in the CAP.
Prioritization and Evaluation of Issues
Based on the review of PIPs sampled during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the PIP categorization guidance in NSD 208. Each PIP was assigned a significance level by the Centralized Screening Team and adequate consideration was given to system or component operability and associated plant risk.
The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees 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 depending on the type and complexity of the issue, consistent with NSD 212.
Effectiveness of Corrective Actions
Based on a review of PIPs, interviews with licensee staff, and verification of completed corrective actions, the team 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, PIPs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred.
Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective.
- (3) Findings
No findings were identified.
b.
Assessment of the Use of Operating Experience (OE)
- (1) Inspection Scope
The team examined licensee programs for reviewing industry OE, reviewed licensee procedure NSD 204, Operating Experience Program, and reviewed and selected PIPs to assess the effectiveness of how external and internal OE data was handled at the plant. In addition, the team selected a sample of OE 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 November 2010, to verify whether the licensee had appropriately evaluated each item for applicability, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.
- (2) Assessment
Based on a review of documentation related to review of OE issues, the team determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated and 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. In addition, OE was included in apparent cause and root cause evaluations in accordance with licensee procedure NSD 204.
- (3) Findings
No findings were identified.
c.
Assessment of Self Assessments and Audits
- (1) 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 NSD 607, Self Assessments and Benchmarking. Documents reviewed are listed in the Attachment.
- (2) 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 teams independent review. The team verified that PIPs were created to document all 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.
- (3) Findings
No findings were identified.
d.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope
The team interviewed 16 randomly selected on-site workers regarding their knowledge of the CAP and their willingness to write PIPs or raise safety concerns. Also, during technical discussions with members of the plant staff, the team conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The team reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the team reviewed a sample of PIPs generated as a result of issues identified through the ECP to verify that concerns were being properly reviewed. Documents reviewed are listed in the Attachment.
- (2) Assessment
Based on the interviews conducted and the PIPs reviewed, the team 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 team determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The team did not identify any reluctance on the part of the licensee staff to report safety concerns.
- (3) Findings
No findings were identified.
4OA6 Meetings, Including Exit
On November 8, 2012, the team presented the inspection results to Mr. Scott Batson and other members of the licensees staff. Proprietary information reviewed during the inspection was returned to the licensee or destroyed in accordance with prescribed controls.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Batson, Plant Manager
- A. Driver, Licensing Engineer
- K. Henderson, Catawba Site Vice President
- B. Jones, Performance Improvement Manager
- C. Kamilaris, Organizational Effectiveness Manager
- T. Pasour, Regulatory Compliance
- S. Putnam, Nuclear Safety Assurance Manager
- L. Rudy, Regulatory Compliance Manager (Acting)
- P. Simbrat, Senior Operations Specialist
NRC Personnel
- R. Cureton, Resident Inspector, DRP, Catawba Resident Office
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None