IR 05000413/2022011

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Biennial Problem Identification and Resolution Inspection Report 05000413/2022011 and 05000414/2022011
ML22343A232
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 12/15/2022
From: Eric Stamm
NRC/RGN-II/DRP/RPB1
To: Simril T
Duke Energy Carolinas
References
IR 2022011
Download: ML22343A232 (12)


Text

SUBJECT:

CATAWBA NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2022011 AND 05000414/2022011

Dear Tom Simril:

On November 17, 2022, 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 problem identification and resolution 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 problem identification and resolution 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.

December 15, 2022 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, Eric J. Stamm, Chief Reactor Projects Branch 1 Division 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:

05000413/2022011 and 05000414/2022011

Enterprise Identifier:

I-2022-011-0028

Licensee:

Duke Energy Carolinas, LLC

Facility:

Catawba Nuclear Station

Location:

York, South Carolina

Inspection Dates:

October 31, 2022, to November 17, 2022

Inspectors:

M. Checkle, Senior Allegations Coordinator

D. Jackson, Senior Project Engineer

N. Lacy, Operations Engineer

D. Rivard, Resident Inspector

E. Robinson, Project Engineer

Approved By:

Eric J. Stamm, Chief

Reactor Projects Branch 1

Division of Reactor Projects

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

Type Issue Number Title Report Section Status LER 05000414/2022-001-00 LER 2022-001-00 for Catawba Nuclear Station,

Unit 2, Manual Reactor Trip and Auxiliary Feedwater Start due to Misaligned Control Rods 71153 Closed

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 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution (PI&R) program in identifying, prioritizing, evaluating, and correcting problems.

The inspectors conducted an in-depth corrective action program review of the following systems/components or portions thereof: auxiliary feedwater, emergency diesel generators, nuclear service water, standby shutdown facility. The inspectors also conducted a five-year review of equipment aging issues.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through 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.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event report (LER):

(1) LER 05000414/2022-001-00, Catawba Nuclear Station, Unit 2, Manual Reactor Trip and Auxiliary Feedwater Start due to Misaligned Control Rods (ADAMS Accession No. ML22173A172). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

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 (which includes the work management system), 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. 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, work orders, and work requests, the inspectors concluded that problems were prioritized and evaluated in accordance with licensee guidance. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that, in general, 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, generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused.

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 team determined that the stations processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.

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. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that action requests were created to document areas for improvement and findings, and verified that actions generally had been completed consistent with those recommendations.

However, the inspectors noted that during the licensees 2020 PI&R readiness self-assessment, the licensee identified that both the work order backlog biennial assessment, and the annual work order and work request backlog review, had not been completed for 2019 and 2020, respectively, as required by AD-WC-ALL-0200, On-line Work Management. Along with other corrective actions, the licensee completed the assessment in November 2020. During the 2022 PI&R readiness self-assessment, the licensee identified that the 2022 work order backlog biennial assessment had not been scheduled for 2022 (although it was required to be scheduled by December 31, 2021, and was due November 2022). Additionally, the licensee identified that the annual work order and work request backlog review had not been performed for 2021. This led the licensee to deem the corrective actions from the 2020 PI&R readiness self-assessment, ineffective. The licensee initiated additional corrective actions to further address the concerns (nuclear condition report 2431519).

4) Safety-Conscious Work Environment Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available. Based on interviews with plant staff and reviews of the latest safety culture survey results, the team found no evidence of challenges to a safety conscious work environment.

EXIT MEETINGS AND DEBRIEFS

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

On November 17, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Tom Simril and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective Action

Documents

2143837

2176144

2181760

266064

2300974

2302626

2302634

2302706

2302707

2303887

2305356

2342017

2344352

2347098

2347364

2350950

2351187

2351615

2354956

2356199

2356298

2356772

2356974

2357189

2358529

2359785

2359991

2359993

2362709

2363667

2363831

2364311

2364647

2367070

2367367

2367381

2367457

2367459

2367784

2368553

2371723

2373019

2373374

2375740

2375813

2375996

2376022

2379984

2383078

2383228

2385280

2388798

2389432

2390261

2393718

2393733

2396503

2397351

2397949

2398462

2398745

2398921

2399490

2401326

2401560

2401927

2402459

2402479

2402590

2402710

2405297

2406502

2407902

2408205

2409314

2409746

2410295

2412065

2414079

2414669

2415834

2415837

2415847

2416012

2416660

2418051

2418833

2419020

2419447

2419894

2419921

20233

21239

21877

22817

23905

23924

24201

24572

25057

25058

25552

25952

26694

26696

26981

27097

27164

27166

27202

27313

27521

27709

28747

28876

29628

29958

2430385

2430551

2431369

2431604

2431876

2432589

2433334

2434704

2435040

2436428

2437364

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2438983

2439872

2440019

2441971

2442864

2446617

2446695

2446709

2449795

AD-EG-PWR-1611

Boric Acid Corrosion Control Program - Implementation

AD-MN-ALL-0005

Nuclear Planning

AD-MN-ALL-0006

Fluid Leak Management

AD-PI-ALL-0100

Corrective Action Program

AD-PI-ALL-0106

Cause Investigation Checklists

AD-PI-ALL-0300

Self Assessment and Benchmark Programs

AD-PI-ALL-0400

Operating Experience Program

AD-RP-All-5004

Vendor Cask Manuals

AD-SY-ALL-0150

Reporting Safeguards, Security, and Fitness for Duty Events

AD-WC-ALL-0200

On-line Work Management

AD-WC-ALL-0210

Work Request Initiation, Screening, Prioritization, and

Classification

PD-EG-PWR-1611

Boric Acid Corrosion Control Program

Procedures

PY-NO-ALL-0200

Safety Conscious Work Environment

Work Orders

20185290

20185319

200107

205433

207878

209822

217938

218885

218957

221948

224290

224292

224775

224800

227008

232203

235665

235730

235752

235764

20433802

20437028

20454103

20454285

20454439

20455267

20458094

20462695

20468790

20469906

20475234

20475243

20475246

20484562

20499660

20503389

20503499

20519244

20526623

20531056

20534464

20559079

20431816

20434005

20454439

20459965

20485842

20495382

20499660

20503389

20531056

20534464

71152

Corrective Action

Documents

Resulting from

Inspection

2449795

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71153

Corrective Action

Documents

24761