IR 05000413/2018011

NRC Problem Identification and Resolution Inspection Report 05000413/2018011 and 05000414/2018011

ML18324A513
Person / Time
Site:	Catawba
Issue date:	11/20/2018
From:	Frank Ehrhardt NRC/RGN-II/DRP/RPB1
To:	Simril T Duke Energy Carolinas
References
IR 2018011
Download: ML18324A513 (11)

Text

November 20, 2018

SUBJECT:

CATAWBA NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION REPORT 05000413/2018011 AND

05000414/2018011

Dear Mr. Simril:

On October 18, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Catawba Nuclear Station Units 1 and 2. On that date, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed inspection 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. The team did not identify any findings or violations of more than minor significance.

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. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Frank Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects

Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

IR 05000413/2018011 and 05000414/2018011

Inspection Report

Docket Numbers:

50-413, 50-414

License Numbers:

NPF-35, NPF-52

Report Numbers:

05000413/2018011 and 05000414/2018011

Licensee:

Duke Energy Carolinas, LLC

Facility:

Catawba Nuclear Station, Units 1 and 2

Location:

York, SC 29745

Inspection Dates:

October 1, 2018 to October 18, 2018

Inspectors:

M. Toth, Project Engineer, Team Lead

K. Kirchbaum, Operations Engineer

J. Parent, Resident Inspector (Oconee Nuclear Station)

C. Scott, Resident Inspector (Catawba Nuclear Station)

Approved By:

F. Ehrhardt, 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 problem identification and resolution inspection at Catawba Nuclear Station Units 1 and 2 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. No findings or violations of more than minor significance were identified.

Identification and Resolution of Problems

The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized and corrected. The licensee effectively identified problems and entered them into the corrective action program for resolution. Generally, prioritization and evaluation of issues were adequate, cause evaluations were adequate, and corrective actions specified for problems were acceptable. Corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.

The inspectors determined that audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the corrective action program, and appropriate corrective actions were developed to address the issues identified. The licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the corrective action program. The licensee appropriately incorporated industry and internal operating experience in its 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 use the corrective action program to resolve those concerns.

INSPECTION SCOPE

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.

71152 - Problem Identification and Resolution

Biennial Team Inspection (1 Sample)

The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment. The assessment is documented below.

(1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions - The 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.

(2) Operating Experience and Self-Assessments and Audits - The team evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

(3) Safety-Conscious Work Environment - 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.

INSPECTION RESULTS

Corrective Action Program Effectiveness Assessment 71152Problem Identification and Resolution

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.

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 for any reason. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.

The inspection team identified one issue of concern regarding a failure to identify a condition adverse to quality associated with the containment penetration valve injection system (NW).

The licensee missed several opportunities to initiate a nuclear condition report (NCR) and subsequently re-evaluate their original operability determination after learning new information on what caused a 1NW-61B stroke test failure on April 24, 2018. This issue was entered into the licensees corrective action program as NCR 02210581 and is documented as a minor violation in the table below.

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 team reviewed condition reports and effectiveness reviews to verify 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.

Minor Violation 71152Problem Identification and Resolution

Minor Violation: 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, the licensee failed to follow AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Step 5.1.1.2, and AD-PI-ALL-0100, Corrective Action Program, Steps 5.2 and 5.9.1 to address an undesired condition after learning 1NW-61B was potentially susceptible to a pressure locking condition, until the NRC questioned valve operability on May 30, 2018. The failure to initiate an NCR for a condition adverse to quality was a performance deficiency.

Screening: The inspectors answered no to the more than minor screening questions in IMC 0612 Appendix B Issue Screening, dated January 1, 2018. The inspectors determined the response to the issue was appropriate, and included the licensee: 1) entering the issue into the corrective action program, 2) revising the original immediate determination of operability, and 3) conducting a prompt determination of operability. The licensee subsequently changed 1NW-61B to operable but degraded/non-conforming (OBDN). Additionally, the licensee had implemented an engineering change to modify affected valves to address pressure locking concerns and has long term plans in place to change affected valves to a different style.

Enforcement:

The failure to comply with procedural requirements constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Operating Experience, Self-Assessments, and Audits Assessment 71152Problem Identification and Resolution

The team determined that stations 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 team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. 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.

Safety Conscious Work Environment Assessment 71152Problem Identification and Resolution 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 team found no evidence of challenges to safety-conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure. No proprietary information was documented in this report.

• On October 18, 2018, the inspectors presented the problem identification and resolution inspection results to Mr. Tom Simril and other members of the licensee staff.

DOCUMENTS REVIEWED

Procedures

AD-EG-ALL-1210, Maintenance Rule Program

AD-PI-ALL-0100, Corrective Action Program

AD-PI-ALL-0101, Root Cause Evaluation

AD-PI-ALL-0102, Apparent Cause Evaluation

AD-PI-ALL-0103, Quick Cause Evaluation

AD-PI-ALL-0106, Cause Investigation Checklists

AD-PI-ALL-0200, Performance Trending

AD-PI-ALL-0300, Self-Assessment and Benchmark Programs

AD-PI-ALL-0400, Operating Experience Program

AD-PI-ALL-0401, Significant Operating Experience Program

AD-MN-ALL-1000, Conduct Of Maintenance

AD-NO-ALL-0202, Employee Concerns Program

AD-NO-ALL-0305, Integrated Scheduling of Audits and Assessments

AD-OP-ALL-0105, Operability Determinations and Functionality Assessments

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

AD-WC-ALL-0200, On-Line Work Management

AD-WC-ALL-0210, Work Request Initiation

CSD-AD-ALL-0004, Corrective Action Program Review Meeting

PY-NO-ALL-0200, Safety Conscious Work Environment

PT/1/A/4200/027, NW Valve Inservice Test (QU), Rev. 51

PT/2/A/4200/027, NW Valve Inservice Test (QU), Rev. 41

Condition Reports

2064318, 02074148, 02084898, 02107777, 02122992, 02129573, 02136400, 02146819,

2181261, 02185079, 02190178, 02195072, 02199882, 02222108, 02223943, 02157978,

2161153, 02166032, 02181760, 02204792, 02196926, 02196923, 02213190, 02200758,

2172410, 02214326, 02059564, 02136211, 02162448, 02186868, 02062216, 02138520,

2164027, 02195535, 02092786, 02143916, 02164030, 02195969, 02105977, 02144146,

2164035, 02201404, 02110246, 02144147, 02164149, 02202200, 02120335, 02148339,

2164595, 02202959, 02122747, 02153594, 02166112, 02203279, 02122966, 02155375,

2166117, 02209372, 02131012, 02161894, 02183163, 02209317, 02133728, 02163935,

2186215, 02211000, 02134441, 02162426, 02186352, 02211589, 02211648, 02212222,

215227, 02217122, 02222823, 02222860, 02223348, 02223367, 02223679, 02225143,

01511021, 01518684, 01994011, 02062582, 02063385, 02063397, 02064098, 02064285,

2064370, 02065328, 02066315, 02067646, 02068985, 02069206, 02073302, 02074228,

2074767, 02074958, 02075447, 02075831, 02088040, 02088105, 02090381, 02091002,

2091742, 02096392, 02116611, 02124814, 02125828, 02128828, 02130226, 02131514,

2133968, 02140709, 02141949, 02150640, 02157826, 02161247, 02166418, 02171420,

2180242, 02184267, 02190684, 02192377, 02193251, 02193253, 02197271, 02200103,

201062, 02207993, 02207996, 02207999, 02208012, 02208019, 02208358, 02209977,

210001, 02210581, 02210790, 02211400, 02211589, 02211616, 02211750, 02218463,

220387, 02224187, 02231859, 02232997, 02060396, 02093776, 02201116, 02091858,

2123923, 02124109, 02125341, 02125747, 02126103, 02134011, 02141080, 02141460,

2149089, 02152126, 02157340, 02157935, 02172574, 02179608, 02180289, 02186215,

2192589, 02195413, 02198878, 02209245, 02097829, 02102687, 02124131, 02146568,

2157218, 02159774, 02173258, 02195926, 02196713, 02201785, 02086505

Self-Assessments, Audits, and Trend Reports

2016-FLEET-CAP-01, Nuclear Oversight Audit, Fleet Corrective Action Program

2018-FLEET-CAP-01, Nuclear Oversight Audit, Fleet Corrective Action Program

CNS Performance Trending Report, 1st Triannual Period 2018

CNS Performance Trending Report, Operations 1st Triannual Period 2018

CNS Performance Trending Report, Engineering 1st Triannual Period 2018

CNS Performance Trending Report, Radiation Protection 1st Triannual Period 2018

Work Orders

2074046

2074044

2106566

2110858

2001347

256970

20114745

2106566-01

2106566-05

2106566-06

2106566-07

2110858

20191853-01

20191853-03

20191853-04

20191853-09

20174347-01

263667-01

20045369

20070371

20104943

20109512

256969

256974

256976

Other

Duke-QAPD-001, Duke Energy Corporation Topical Report, Quality Assurance Program

Description, Operating Fleet, Amendment 43

CNS-1609.VG-04-0001, Diesel Generator Engine Start Air System (VG) Design Basis

Specification, Rev. 18

Maintenance Rule Information Document for Engineers, Rev. 0

Engineering Change (EC) 412435

CN-1492-NW.00-121, Auxiliary Building Containment Valve Injection Water System, Rev. 3

CN-1492-NW.00-123, Auxiliary Building Containment Valve Injection Water System, Rev. 3

CN-2492-NW.00-156, Auxiliary Building Containment Valve Injection Water System, Rev. 1

CN-2492-NW.00-158, Auxiliary Building Containment Valve Injection Water System, Rev. 2

CN-1569-01.00, Flow Diagram of Containment Valve Injection Water System, Rev. 28

CN-2569-01.00, Flow Diagram of Containment Valve Injection Water System, Rev. 28A

MR Eval-CN-14-2031

2015 Inspection Report for Civil Engineering Structures and Components Per EDM-410 Final

Report